Bryan Haywood

For CAA section 112(r)(1), General Duty, what are the chemicals that are covered?

There is no specific list of substances that subjects a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources that have any “extremely hazardous substances”. Extremely hazardous substances are NOT limited to the list of regulated substances listed under section 112(r), […]

Must separate amounts of regulated substances be aggregated for threshold determinations?

Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary

When your “life safety equipment” inspector is violating your HAZLOC requirements!

PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working. We

I asked AI to explain why Line Breaks are so hazardous

In an industrial and occupational safety context, a line break accident occurs when workers open pipes, valves, flanges, or vessels containing hazardous materials—such as toxic chemicals, flammable liquids, high-pressure gases, or high-temperature steam—and an unintended release occurs. Because these accidents can result in severe chemical burns, toxic inhalation, explosions, or physical trauma from pressure blasts,

Understanding 1910.147(d)(5)(ii) (Reaccumulation of Energy)

OSHA 1910.147(d)(5)(ii) is one of the most critical, yet frequently overlooked, requirements of the Lockout/Tagout (LOTO) standard. It moves LOTO from a static, one-time task (“lock it and check it”) to a dynamic process that accounts for the physical reality of residual and regenerative energy. Think about isolating “compressed air” to a machine/equipment and the

Waste management company fined $130,000 after workers were injured in a flash fire caused by a Vac Truck

Four (4) workers were injured at a worksite on April 30, 2024, while offloading flammable solvents from a vacuum truck into a storage tanker. At the same time, other workers positioned a hydrovac truck in an adjacent bay to offload a wastewater-and-slurry mixture. During this process, flammable vapors were released and drawn into the idling

Interesting Lawsuit against Company (Fire Watch issues)

An independent contractor in Denton, Texas, was severely burned and fell from an extension ladder after his clothing ignited during a flash fire. The worker was torch-cutting steel walls on a transformer unit to dismantle it for a scrapyard. A lawsuit filed in late June alleges the provided fire watch was improperly positioned and inattentive.

Line Break gone bad (Flammable Gas)

Sinopec Yangzi Petrochemical (May 29, 2026): Four workers died during shutdown maintenance at an ethylene plant in China. The flash fire occurred while operations personnel were disassembling a cracking valve. Early investigations point to incomplete emptying and purging of the pipe, which left residual cracking gases (ethylene, propylene, and butadiene) inside. The suspected ignition source

OSHA emergency response standard update

The proposed OSHA Emergency Response standard is currently in the final review stages. According to OSHA’s most recent Unified Agenda (published in July 2026), the final rule is projected to be published in April 2027. Once finalized, this rule will completely replace the outdated 1980 “Fire Brigades” standard (29 CFR 1910.156) and dramatically expand basic

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