Bryan Haywood

US Department of Labor announces new rules to adjust civil penalty amounts

In 2015, Congress passed the Federal Civil Penalties Inflation Adjustment Act Improvements Act to advance the effectiveness of civil monetary penalties and to maintain their deterrent effect. The new law directs agencies to adjust their penalties for inflation each year using a much more straightforward method than previously available, and requires agencies to publish “catch…...

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A baseline for Pressure Vessel Safety in the USA

Every once in a while we come across process vessels that are operating well above 15 psi and yet the vessel has no recognized design criteria and is far from being an ASME “coded vessel”.  Most of the time the client is happy we discovered this, but there are those who will always challenge the…...

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2016 Video of the Week #26 (Overhead Items are NEVER safe)

One of the top items from our process safety audits, PHAs, assessments, etc. is the lack of vehicle protection around critical equipment/infastructure.  Number one target in process plants is overhead piping!  It seems no matter how high we put it, it will get hit.  Already this year we were told that the pipe bridge over…...

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PSM/RMP Application and NFPA 704 Ratings

One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule.  I hope to clarify any confusion this NFPA 704 application may be causing, as YES – the NFPA 704 does have a role in determining if…...

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EPA RMP Citations @ refinery (Flammables, Toxics & $165K)

Respondent owned and operated a refinery. On March 31-April3, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The refinery submitted a single RMP with covered processes that are subject to Program 3 requirements. The regulated flammable substances that are above the threshold…...

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UPDATE on OSHA’s PSM Revisions (June 2016)

OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA’s Process Safety Management Program (PSM) standard.  The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA’s 2013 Request for Information and lessons learned from accidents…...

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Accident Investigation Principles (DOE)

The basis for conducting any event investigation is to understand the organizational, cultural, or technical factors that, left unattended, could result in future accidents. Guiding concepts may be summarized as follows:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA PSM citations @ food additive manufacturer (Flammables & $180K)

A food additive manufacturer’s failure to handle hazardous materials and respond properly to an emergency led to an explosion that injured four workers, including two contractors who scaled an 8-foot security fence topped with triple-strand barbed wire to escape the fireball.  An OSHA investigation found the business violated process safety management procedures for the handling…...

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OSHA PSM citations @ cold storage facility (NH3 & $54K)

July 7, 2016 UPDATE – Company is Contesting all citations OSHA has issued nine serious safety violations to a food industry provider of cold storage warehousing and logistical services. A January 2016 complaint investigation found the company violated OSHA’s process safety management procedures for using ammonia in its refrigeration warehouse facility. An investigation by the…...

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