Bryan Haywood

EPA RMP Citations @ aerosol propelled adhesive facility (LPG/Butane & $100K)

The Respondent’s July 23, 2019, RMP submission outlines a maximum inventory of the regulated flammable substance butane and LPG at the Facility that exceeds the threshold quantity of 10,000 pounds of butane and LPG as outlined in Table 3 at 40 C.F.R. § 68.130. Respondent’s aerosol-propelled adhesive process at the Facility was, at the time…...

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Understanding IDLH

There are more than 380 substances with IDLH limits. View the current list of substances with IDLH. You can also find IDLH values in CAMEO Chemicals or in the online version of the NIOSH Pocket Guide(link is external). IDLH limits were primarily established to aid in making informed decisions about respirator use. Above the IDLH,…...

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Emergency Response and the state of NJ’s Right to Know Hazardous Substance Fact Sheets

FYI… the state of NJ’s Right to Know Hazardous Substance Fact Sheets are the bomb and with WISER gone, these move up to my #1 go-to ER document. We need three (3) reliable sources to formulate our Incident Action Plan (IAP) that includes our PPE Hazard Assessment. These Fact Sheets, NIOSH’s Pocket Guide Book, and…...

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Pressure Vessels and SIF

As we have discussed many times, I am a strong advocate of the SIF approach to risk management. Growing up in the PSM arena, we realize that the entire process safety effort is built on the SIF model. However, for those unfamiliar with managing catastrophic risks, SIF can become just another “flavor of the year”…...

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The OSHA HAZWOPER requirement 99% of Industrial facilities fail to meet

There is one requirement in the HAZWOPER standard that has been in place since its promulgation, which almost every industrial facility with its own internal HAZMAT response team fails to meet. I receive a significant amount of pushback when I cover this OSHA minimum requirement, and I am always as shocked by the response as…...

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What is the “Shingle” effect, and WHY is it so critical in PPE usage?

If we pay close attention to PPE pictures, especially at Emergency Responses, we can see that this critical aspect of proper PPE donning is usually not followed, placing responders at increased risk. So, what is the PPE Shingle Effect, and WHY is it REQUIRED?… Membership Required You must be a member to access this content.View...

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The three (3) pieces of Chemical Data one must know when performing a risk analysis

You get to pick ONLY three (3) pieces of data about a chemical you have responded to. You know the chemical, so what would the three (3) pieces of data you would want to know be and why? Here are my three and why…… Membership Required You must be a member to access this content.View...

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OSHA’s current interpretation of the HAZWOPER standard as it relates to IDLH operations

Here is OSHA’s current interpretation of the HAZWOPER standard as it relates to IDLH operations. The LOI specifically addresses the HAZWOPER requirement for workers who are engaged in remedial operations as well as in emergency response operations in atmospheres that are or may be IDLH AND who utilize self-contained breathing apparatus (SCBA) for the control…...

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For the initial entry into the hot or warm zone, LEVEL B PPE is the ABSOLUTE MINIMUM

WARNING! If you have an ER instructor who claims you can enter the Hot or Warm zone the first time in using LEVEL C PPE, you need to fire them! I have been conducting HAZMAT training for 28 years, and every year, I pick up a few new ER clients who need a refresher course…....

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Air compressors and receivers can pose catastrophic risks

Just about every manufacturing facility will have a compressed air system. Some of these may be the size of what some of us have in our garages, but many will be industrial-sized units. BOTH sizes pose catastrophic risks. As shown in this United Steel Workers Incident Alert, these catastrophic failures can cost lives and jobs…....

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EPA RMP Citations @ NH3 Storage facility (NH3 & $460K)

Respondent operated a facility (the “Facility”) that stores and distributes anhydrous ammonia. The Facility receives anhydrous ammonia from oceangoing vessels and stores it in two interconnected insulated tanks. The Facility includes three pressure tanks storing fertilizer-grade ammonia (Fl through F3) and four pressure tanks storing refrigeration-grade ammonia (R1 through R4). Respondent produces, stores, and distributes…...

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OSHA updates penalty guidelines to support small businesses and eliminate workplace hazards

Penalty adjustments aim to improve workplace safety WASHINGTON – The U.S. Department of Labor has updated its guidance on penalty and debt collection procedures in the Occupational Safety and Health Administration’s Field Operations Manual in an effort to minimize the burden on small businesses and increase prompt hazard abatement. “All employers should be offered the…...

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