Bryan Haywood

Updating your RMP OCA Populations

Back in September 2013 (Members CLICK HERE) I updated you on the fact that LANDVIEW was going away and how this would impact us this year when it comes time to make our 5-year update.  Now for those of you who are using ALOHA/MARPLOT to plot your Off-Site Consequence Analysis you can get your 2010 census…...

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RISK MANAGEMENT PLAN CO-LOCATION GUIDANCE OF NON-INTERCONNECTED REGULATED SUBSTANCE VESSELS (OH EPA)

 Although this “guidance” is provided by Ohio EPA and is meant for ONLY facilities located in the state of Ohio, this guidance is an EXCELLENT breakdown of how a facility should view “co-located” containers of their Extremely Hazardous Substances to determine if their “co-located containers/vessels” are actually a “process” that would fall under the CAA’s…...

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Food Processing Company Settles Violations of Chemical Release Reporting Requirements (NH3 Refrigeration)

EPA announced that a food processing facility has agreed to pay a $19,049 penalty for failing to properly report an ammonia release at its facility.  According to EPA, the facility released at least 450 pounds of anhydrous ammonia to the air on September 12, 2012. Employees were evacuated and the local Fire Department responded to a 911…...

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37 incidents & 0 updates (2/9/14)

  MANY THANKS to my NEWEST and RENEWING Partners in Safety since 2006 since 2014 returning partner from 2012 since 2014   2014 Fatality Tracker Electrical 6 (2013 = 32) (2012 = 68) Forklift/Manlift 7 (2013=62) (2012 = 52) Mining* 5 2013=87*) (2012 = 92*) *no longer includes China accidents Explosions 23 (2013=194) (2012 =…...

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ACGIH® Board Ratifies 2014 TLVs® and BEIs®

The ACGIH® Board of Directors ratified the 2014 Threshold Limit Values (TLVs®) for Chemical Substances and Physical Agents and Biological Exposure Indices (BEIs®) on December 13 and 19, 2013 and on January 27, 2014. The Board also approved recommendations for additions to the Notice of Intended Changes (NIC). For a listing of the substances that were acted upon, click here. The…...

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Process Safety Operating Procedures and a Certified PPE Hazard Assessment

This week, OSHA once again showed their intent to issue PPE citations during PSM NEP audits.  They are very content to issue a citation against 1910.132(a) or (d) when the process contains a flammable liquid and somehow the employer’s PPE Hazard Assessment determined that Flame Retardant Clothing (FRC) is not necessary.  But there is another…...

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Is your facility REALLY prepared for an emergency? (ERT and PSM SOPs)

Over the past several months we have been working with a confidential client who has afforded me with permission to post this “learning opportunity” for others.  This incident, although minor this time, was recognized as having the potential to end the business so this organization is pulling out all the stops to identify failures.  Once…...

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OSHA PSM citations @ films and packaging manufacturer (Flammables & $112,500)

A plant that produces films used in packaging has been cited by OSHA for 19 PSM related violations. The plant has been cited for exposing workers to flammable chemicals. OSHA has proposed penalties of $112,500. The inspection was initiated in July 2013 under OSHA’s PSM NEP and found employees were exposed to health and safety…...

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EPA RMP General Duty Citations @ cold storage warehouse (NH3 & $MILLIONS)

This case may be the “whopper” that sinks the General Duty Clause perverbal teeth into the refrigeration industry.  From all accounts, it appears this facility was inspected and issued some NOVs, which the facility agreed to take care of.  A year later, EPA returned for a follow-up inspection and found items not corrected. Here are…...

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EPA RMP Citations @ refrigerated distribution center (NH3 and $1K)

On August 10, 2012, EPA conducted a compliance inspection of a refrigerated Distribution Center to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the August 10, 2012 inspection, EPA has determined that Respondent violated the…...

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