Bryan Haywood

OSHA PSM citations @ warehousing and logistics facility (NH3 & $58K)

OSHA initiated the October 2015 inspection following a report of an ammonia release (apparently during a manual purge of NH3) at the warehousing and logistics company. The agency cited the company for nine serious violations, six for process safety management standards violations, two for not fit testing or providing a medical evaluation of employees before […]

Pipe flanges, screwed connections, fittings, valves, meters, etc. and our Hazardous Locations

When establishing our Hazardous Locations (HAZLOC) we utilize a Recognized And Generally Accepted Good Engineering Practice (RAGAGEP) such as NFPA 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas or there is also API RP500, Recommended Practice for Classification of Locations

Inside look at OSHA’s desired PSM revisions

Potential PSM scope items: Clarifying the exemption for atmospheric storage tanks Removing the exemption for Oil- and Gas-Well Drilling and Servicing Resuming Enforcement for Oil and Gas Production Facilities Covering reactive chemical hazards Updating and expanding the list of HHCs in Appendix A of the existing PSM standard Covering dismantling and disposal of explosives and

Use of Aftermarket Replacement Component Parts for NIOSH-Approved Respirators (NIOSH)

Worker safety can be compromised by using replacement component parts or accessories that are not NIOSH-approved for the specific respirator. Although NIOSH-approved respirators are comprised of various component parts, they are approved as a complete unit. The use of components which are not part of the approved assembly results in a respirator that has not

Revised Interim Enforcement Procedures for Reporting Requirements under 29 C.F.R. 1904.39

This memorandum provides updated internal guidance and procedures for the Area Offices to enforce the reporting requirements. Among other things, this memo updates the procedures for the intake of reports from employers, data collection and sorting; and entry of data in the OIS system.  Revised flow charts are provided to help understand the intake process.

EPA RMP GDC citations @ chemical plant (Polyvinyl Chloride (PVC) & $33K)

This investigation began after a 9.6 pound vinyl chloride release from an improperly installed rupture disc (RD). The rupture disk had been improperly installed per original design, and its identification tag had been improperly inserted in the rupture disc holder.  Just last night I posted an incident where a “low pressure” vessel catastrophically failed because it did

Cost–Benefit Analysis of Proposed California Oil and Gas Refinery Regulations (RAND Corp)

The research reported here assessed the costs and benefits of the proposed California process safety management (PSM) and California Accidental Release Prevention regulations that are designed to improve safety at oil and gas refineries in California. The authors estimate these costs and benefits in four categories: costs to industry (to implement the regulation), costs to

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