Bryan Haywood

UPDATED: Why are industries exempt under OSHA’s PSM subject to RMP?

The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA’s process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements?… Membership Required You must be a member...

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UPDATED: Why are industries exempt under OSHA’s PSM subject to RMP? Read More »

Does the distance to endpoint start at the process or stationary source boundary?

When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the “greatest distance to an endpoint” refer to the greatest total distance from the process (e.g.,…...

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OSHA PSM citations @ Food plant (NH3 & $64K)

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The SIF debate is alive and well in the EHS community

For me, SIF is just using Process Safety Management (PSM) tools for lower-frequency, higher-severity events, whereas traditional “recordable injuries” can be managed with the traditional Safety Management System (SMS). But here is the catch… the consequence may be more severe (serious), but the failures that led to those consequences can all be traced back to…...

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Safety Thought of the Week & more defending of H.W. Heinrich’s work

Heinrich did not blame workers for accidents—quite the opposite. He was more in the camp of Latent Organizational Failures, as James Reason taught us in the 1980s. In this passage from his 1928 article “The Origin of Accidents”, Travelers, we can see his position on accidents on full display… Remember, he said this 96 years…...

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State Emergency Response Commission Survey 

In April 2023, EPA published a report on the first survey conducted of the State Emergency Response Commissions. The purpose of the survey was to learn how the Emergency Planning and Community Right-to-Know Act is currently implemented at the state and local levels, as required by the 1986 legislation, as well as its amendments of…...

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Not following National Board code for repairs to PVs can be very costly

On Dec. 3, 2004, a 50,000-pound steel pressure vessel violently exploded at the southwest Houston Marcus Oil and Chemical facility. The pressure vessel contained flammable hydrocarbons such as hexane. The pressure vessel was a horizontal tank 12 feet in diameter, 50 feet long, and operated at a pressure of approximately 67 psi. Marcus Oil did…...

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Residual FLAMMABLE VAPORS in PVC pipe cause explosion

On September 13, 2007, a subcontractor was implementing a hot tap into a carbon steel pipe. The explosion was caused by the heat from the acetylene torch kindling the residual vapor inside, attaching to the polyvinylchloride (PVC) piping. Shrapnel pieces were blown up to 100 feet outwards due to the force of the explosion. The…...

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Leak Testing a PV kills worker

On January 15, 2008, a pressure vessel at a New Jersey foundry exploded, killing one 60-year-old worker instantly while injuring eight other workers with shrapnel. The pressure vessel in question was used to pressurize/depressurize molten aluminum to prevent/eliminate porosity from the metal. The incident occurred while two (2) workers, including the one who was killed,…...

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Halon Cylinder is dropped and becomes projectile

In June 2008, a cylinder was dropped, and its top valve hit a concrete platform. The impact of the cylinder valve on the concrete caused the threads on the screw connection, which held the valve on the cylinder, to fail, resulting in complete separation of the valve from the cylinder. The cylinder’s internal pressure was…...

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Hot Water Heater catastrophically fails, killing two (2) workers

At 11:30 p.m. on March 19, 2009, Solus Industrial Innovations LLC employees from the third shift had just come to work. Their employer is a manufacturer of plastic conveyor parts. One employee (Employee #1) pointed out to the on-shift supervisor that there was a pool of water near an 80-gallon water heater that was being…...

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Compressed Air Receiver Catastrophic Failure

In May 2009, a compressed air tank failed, blowing the bottom off of the tank and sending fragments flying into a concrete wall, puncturing the wall. The investigation following the incidentrevealed several serious problems with the condition of the tank, including severe corrosion and rust at the bottom of the tank, where it failed, and…...

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