Bryan Haywood

A look inside an EPA Consent Decree for HAZWOPER

I still do about a dozen 24 or 40-hr HAZMAT Tech courses and dozens of 8-hr Refreshers each year. And in each class, it never fails that someone will ask the question… Does OSHA/EPA actually require that? Backstory: I’ve been on the ERT for 20 years, and this is the first time I’ve heard this…....

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What constitutes “significant property damage on site?”

Under the hazard assessment requirements at 40 CFR Part 68, Subpart B, the owner or operator of a covered stationary source must document a five-year accident history that includes all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths injuries, evacuations, sheltering in place,…...

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Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)?

Back to an old question that continues to be asked… Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)? The definition of stationary source does not apply to transportation, including storage incident to transportation (40 CFR Section 68.3).  Are chemicals in a tank car (e.g., tanker truck or…...

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Red Light Therapy Wraps are NOT “First-Aid”

OSHA was asked… whether the use of LED (light emitting diode) red light therapy and red light therapy wraps constitute first aid for purposes of OSHA recordkeeping regulations, and also whether this technology could be added to the list of first aid treatments under section 1904.7(b)(5)(ii). OSHA’s response is:… Membership Required You must be a...

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EPA RMP Citations @ chemical manufacturing plant (Oleum, SO2, H2SO4, ATS & $174K)

Respondent owns and operates a chemical manufacturing plant that produces oleum, anhydrous sulfur dioxide, sulfuric acid, and ammonium thiosulfate. Respondent re-submitted an RMP for the Facility on February 11, 2022 (2022 RMP) that identifies the following three covered processes that are subject to the Program 3 requirements of the CAPP:a. Oleum Process, which contains the…...

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Line Break Gone Bad (Cutting into live NH3 pipe)

This stunt has to be one of the riskiest I have seen in my 30+ years in Process Safety. They knew it was a live line, but why it was live is anyone’s guess. It looks as if this may be a “Demolition” job without a pump down, or maybe the plant was just down…...

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Worker Fatality During Attempted Removal of Blind Flange on Cooling Water System

On October 21, 2015, two mechanical technicians were involved in an incident while attempting to remove a blind flange from supply piping on a Magnet Cooling Water (MCW) System. The mechanical technicians were assisting a welder in obtaining final measurements to make the final connections from the MCW system to a new Cell 14 cryostat…...

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Worker seriously injured when sprayed by anhydrous ammonia after failure of flexible rubber hose (WorkSafe Western Australia)

A process worker and colleague were preparing for a scheduled maintenance task in the ammonia storage area of a processing plant.As part of a routine purging operation, the process worker connected a flexible rubber hose via a coupling to a purge connection point. The purge hose was charged with nitrogen, and the valve was being…...

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Trust and distrust in safety leadership: Qualities of importance (study by Natalie Abiodun)

This is a GREAT study, although it was not an extensive study. But when I learned of it from Pete Cutbush, I found the research and thought it was spot on; although that may be my biases shining through. As I was taught by all my former business leaders, leading with safety can influence ALL…...

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Butterfly valve(s) & energy isolation (NH3 process)

Some industries’ RAGAGEPs will call out the risk of using a butterfly valve as an energy isolation device due to its propensity to “leak by”. In this incident, the valve catastrophically failed, releasing NH3, resulting in a worker and a contractor being hospitalized. I do not know if the valve was locked out, but that…...

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