Bryan Haywood

Controlling flow rates of non-conductive flammable liquids

In the world of process safety, we have Safe Upper and Lower limits on a lot of common process parameters, such as pressures, levels, temperatures, etc. Flows on the other hand are quite often overlooked as a critical process parameter and when your HHC/EHS is a non-conductive flammable liquid both FLOW and LEVEL must be…...

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Changes in Regulation of Agricultural Anhydrous Ammonia

The purpose of this letter is to make Agricultural Anhydrous Ammonia handlers in Iowa aware of new Anhydrous Ammonia Standards and changes the adaptation of the new standards and exceptions may bring. On December 15, 2014, CGA (Compressed Gas Association) received a Notification of Final Action on ANSI/CGA G-2.1, 2014, Safety Requirements for the Storage…...

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2015 Photo of the Week #9 (NH3 Placard)

Does anyone notice anything a bit odd about this shipment of HAZMAT?  Even though this is a problem, it is one of my proudest moments as a Safety Professional.  My 10 year old son spotted this on 275 here in our town of Milford, OH.  Can you spot the issue?  The answer is below photo……...

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Do you “certify” your 3-year PSM/RMP compliance audits?

Not a trick question but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o).  What do OSHA and EPA mean by certifying an audit?  Who does this certification? Is this a formal exercise of certifying?  Why did OSHA/EPA use this term in the standard? …...

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Compliance Resource Tip… ecfr.gov

Recently OSHA.gov has been experiencing some serious issues and although it appears to have gotten almost back to normal, sometimes access to standards is lost.  And if you’re like me and do a lot of work in locations where there is no internet connection and you need the standards for a project, here is a…...

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OSHA’s Clarification on effective date of SDSs replacing MSDSs

A lot is going on with HAZCOM this year and the biggest activity is the conversion from the old MSDSs to the new 16 section format for the SDSs.  OSHA recently issued a LOI to clarify the the compliance date… Question: When is an employer required to replace their MSDS collection with revised SDSs in…...

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Consider the assumptions made during a PHA Facility Siting Assessment (Pipe Bridges)

I recently participated in a PHA for a large flammable liquids process and during the “facility siting” portion of the PHA we took a detailed tour of the process. During which, several significant “impact” hazards were identified. Of course, the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the…...

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31 incidents & 2 updates (2/24/15)

  Over 12,000 exclusive unsafe acts/conditions and accident/injuries photos and over 1,100 ppt’s & doc’s from more than 2,782 contributors! 2015 Fatality Tracker Electrical 9 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial 5 (2014 = 60) (2013=62) (2012 = 52) Mining* 8 (2014 = 401) (2013=87*) (2012 = 92*) *ONLY developed nations and…...

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Ohio Combustible Dust Rule (1301:7-7-13 Combustible dust-producing operations)

(A) Section 1301 General (1) 1301.1 Scope. The equipment, processes and operations involving dust explosion hazards shall comply with the provisions of this rule. (2) 1301.2 Permits. Permits shall be required for combustible dust-producing operations as set forth in rule 1301:7-7-01 of the Administrative Code. (B) Section 1302 Definitions (1) 1302.1 Definition. The following word…...

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OSHA Hospitalization, Amputations Reporting Inspection triggers

OSHA issued a memorandum to its Regional Administrators and State Designees on 12/242014.  The memorandum provides Area Offices with guidance on when an on-site inspection is warranted.  OSHA has divided injury and illness reports into three categories.  OSHA will inspect facilities that report an injury or illness that falls into one of the first two…...

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