Bryan Haywood

CAL OSHA’s PROPOSED PSM Standard for Refineries

Here is a nice presentation the California Interagency Refinery Task Force did in June 2015: CAL-OSHA has issued an NPRM for a REVISED PSM Standard.  In addition to proposing changes to existing PSM language, the draft proposal introduces new requirements in the following areas:  damage mechanism reviews hierarchy of hazard controls analysis human factors management of organizational…...

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2014 Video of the Week #38 (Forklifts, Rigging, WillFuls, etc.)

There is NO big surprise at the end, but watch and listen to this plan unfold!  Listen the camera guy laugh about how STUPID this act is and how he is recording it for the “failed log”.  To think anyone makes the claim that “Safety is just common sense” shows that four (4) adult men…...

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Ammonia Explosion 30 years ago this week

For many HAZMAT students, learning that a HAZMAT shipped as a Non-Flammable Class 2 HAZMAT can actually ignite is a sobering fact of emergency response. But when they find out this HAZMAT is anhydrous ammonia (NH3) there is a level of disbelief. But it was this week 30 years ago (9/17/84) at approximately 4:00 p.m.,…...

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PRODUCT SAFETY NOTICE – LADDER SAFETY SYSTEMS USING 3/8 INCH 7X19 STRAND GALVANIZED CABLE

This Notice concerns the DBI-SALA Lad-Saf™ Flexible Cable Ladder Safety System, also known as a “Safety Climb System.” Capital Safety has received a limited number of reports of 7×19 strand carrier cable slippage from the carrier clamp in the top bracket of these ladder safety systems. Although this top bracket design has been used in…...

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EPA RMP Citations @ a dairy processing plant (NH3; $7,500)

On December 3, 2013, EPA conducted a compliance inspection of Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the…...

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Designing for Human Failures

As I have said countless times, we ALL make errors.  This means in situations where those errors carry more severe consequences, such as industrial workplaces, then as safety engineers, it is our role to help the business DESIGN SAFE work tasks.  In HF engineering, we have eight (8) system design principles: Accurate mental models Managing…...

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Conveyors, Duct Work, and your Hot Work Permitting Process

In “general industry” workplaces OSHA has a “General Requirements” standard for conducting Welding, Cutting, and Brazing activities (1910.252). For those working within the battery limits of a PSM/RMP covered process, both OSHA (1910.119(k)(2) and EPA (68.85(b) reference 1910.252(a) as the basics of safely conducting these HW activities. But there is one (1) requirement that we…...

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OSHA’s revised Injury and Illness Reporting may call for an MOC at PSM/RMP facilities

Yes, as many of you have figured out I am a big fan of using the Management of Change process to actually manage changes that may officially be outside the PSM/RMP requirements. But how OSHA changing their injury/illness reporting requirements impact my Process Safety Management System? Here’s how…… Membership Required You must be a member...

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Testimonial for Safety Glasses

The incident just occurred yesterday (8/21/14).  A miner operator (underground coal) was cutting rock bottoms in a mine construction area, when he either hit a rib bolt with the cutter head, or a miner bit sheared in two. In either case, the steel fragment became a high speed projectile and struck the employee in the…...

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Being a SAFETY LEADER is not easy…

A rather well-known “management consultant” back in the ’70s and ’80s was Forrest H. Kirkpatrick and Mr. Kirkpatrick wrote a poem about leadership that hangs on my office wall.  It pretty much sums up what being a safety leader is all about – even though Mr. Kirkpatrick meant for it to be a message to all…...

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OSHA cites a Grain Elevator for 1 willful, 2 repeat, 8 serious violations ($120,120)

A 51-year-old worker was fatally injured when he became engulfed in flowing grain in a railcar load-out elevator. On March 15, 2014, the incident occurred when the worker attempted to remove a jam from a chute while the auger operated. OSHA has cited the company for one willful, two repeat and eight serious safety violations,…...

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