Bryan Haywood

Yes. A facility closure may be considered a material modification to a covered facility. In this case, the facility must complete and submit a revised Top-Screen to the Department of Homeland Security (DHS) within 60 days of the material modification (i.e., its closure), in accordance with 6 C.F.R. § 27.210(d), available at http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=5490ca42ba3517c7c9aec9c47cefc750&r=PART&n=6y1.0.1.1.11. When completing […]

One of the more common omissions in SOPs is the inclusion of all the “safety systems and their functions” involved in the execution of the SOP.  In this article, I will use the task of Truck/Railcar Unloading a Flammable Liquid to demonstrate the types of safety systems and their functions that may need to be

Yes, it is true… 1910.119(g)(2) states “Refresher training shall be provided at least every three years, and more often if necessary…” Please take note that the phrase “at least every” is used preceding the 3-year frequency, as well as OSHA explicitly states “more often if necessary”.  In my 20+ years of developing, implementing and managing

This week the WV Attorney General Office (WVAGO) released their investigation report on the 2014 Elk River Chemical spill.  This incident caused a mandatory Do-Not-Use (Water) order to be issued and more than 300,000 residents and countless businesses in a nine-county radius were without potable water for nine (9) days.  This incident has now been