Bryan Haywood

EPA RMP Citations @ Cold Storage facility (NH3 & $85K)

Respondent is the owner and operator of a facility that stores and circulates anhydrous ammonia through two refrigeration systems at its facility and, therefore, is engaged in a process at its facility. On or about September 13, 2023, a representative of the EPA conducted an inspection of the Respondent’s Facility to determine compliance with Section…...

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Behavior-Based Safety Process (BBSP) and Incident Management

One of the most prominent mistakes organizations make when implementing their Behavior-Based Safety Process (BBSP) is that they still operate under 1990s-era assumptions regarding how they view and manage incident reporting and investigation and the behaviors of personnel involved in those undesired events. An improperly implemented and managed BBSP can create numerous biases, with the…...

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Tanker Truck PRCS Fatality (Fatal Fall)

On January 30, 2025, Employee #1 was working at a trailer truck wash business and had been subcontracted to clean out a trailer tank using a water hose. The business specialized in washing out livestock haulers. Employee #1 entered the tank to continue cleaning. A coworker noticed Employee #1 lying on his side at the…...

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PRCS (Railcar) Fatality (5% O2 Atmosphere)

UPDATED on 8/8/25 with OSHA Citations (All are being contested) At approximately 9:34 a.m. on January 10, 2025, an employee, 35, was directed to enter a 23,737-gallon rail tank car containing residues of PCBs and transformer oil to obtain wipe samples of the interior surfaces. The rail tank car was a permit-required confined space. The…...

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Flaws in using a manufacturer’s SWPF study

Disclaimer: I am NO LONGER a fan of Powered-Air Purifying Respirators (PAPRs). It is not the PAPR’s fault; it is the science behind the increased desire to use PAPRs for all the wrong reasons and how this could be bad news for the users. PAPRs have become increasingly popular over the past decade or so…...

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Simple “safety maturity” or dare I say “culture” test…

Auditing! Whether it’s internal (1st party), 2nd party, or 3rd Party, auditing at a CONSISTENT FREQUENCY is a true sign that management is committed to safety. If the management team asks… “Does OSHA require this audit?”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The APR “change-out” schedule

This aspect of respiratory protection is a SAFETY CRITICAL path when using Air Purifying Respirators (APRs), and in my experience, it is rarely done correctly when it is done at all. I teach my program administrators to do precisely what NIOSH has been stating since 2004. When using the Change Out software, use 1 ppm…...

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Human Factors Exercise (Boat in Lock Video)

Part 1: Is the act shown in the video an: Error? Mistake? Or Violation? Keep in mind that we all make errors, mistakes, and commit violations. Part 2: Which class of error, mistake, or violation? Tips to help:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Trick Question: When can we see an invisible hazardous gas?

We can see some hazardous gases, even at low concentrations, such as Chlorine (Cl2). But some hazardous gases are “clear/invisible”. So, using Anhydrous Ammonia (NH3) as our hazardous gas… What does 300 ppm of Anhydrous Ammonia (NH3) look like? Note: 300 ppm is the IDLH for NH3 For example, there’s a release of NH3. You…...

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Case Study: Hiring Unauthorized Personnel Causes Risk of Explosion at Printing Plant (TSSA)

During the summer of 2023, a potential explosion was averted at an industrial facility in Southern Ontario. A new printing press, not approved for use in Canada, was installed and started to signal operational issues during testing. Further complicating the matter, an unauthorized individual tampered with the gas meter set, creating an unsafe environment and…...

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Case Study: Unnoticed Corrosion Causes Ammonia Leak at a Cold Storage Facility (TSSA)

In the spring of 2024, emergency responders responded to an ammonia leak at a cold storage facility in southern Ontario. The incident occurred on the roof, where a corroded shut-off valve on the hot gas line of an ammonia center evaporator failed, resulting in the release of ammonia gas into the surrounding environment. The cold…...

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