Bryan Haywood

EPA RMP General Duty Citations @ cold storage facility (NH3 & $55,537)

NOTE: this is a GAME CHANGER for the cold storage business!  Now EPA is pulling in the business that is merely leasing space AND the real estate broker who is managing the lease agreement!!  Imagine the shock when a business who is just storing their goods in a cold storage facility receives a NOV from…...

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ANSI Launches Online Portal for Standards Incorporated by Reference

Website Provides Free, Read-Only Access to Private-Sector Documents That Have Been Incorporated into U.S. Government RegulationsThe American National Standards Institute(ANSI) is proud to announce the official launch of the ANSI IBR Portal, an online tool for free, read-only access to voluntary consensus standards that have been incorporated by reference (IBR) into federal laws and regulations…....

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Improving Chemical Facility Safety and Security: Listening Sessions

Please join the Environmental Protection Agency, Department of Homeland Security, Occupational Health and Safety Administration, and several other federal agencies including the Pipeline and Hazardous Materials Safety Administration, for a series of listening sessions on Improving Chemical Facility Safety and Security (Executive Order 13650 (EO).  The first session will be held November 5 in Texas City,…...

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OSHA’s Frequently Asked Questions on HAZWOPER (1910.120)

Who is covered by OSHA’s HAZWOPER standard? The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. This includes any employees who are exposed or potentially exposed to hazardous substances — including hazardous waste — and who are engaged in one of the following operations as…...

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OSHA’s 2013 Most Frequently Cited Standards

The following were the top 10 most frequently cited standards in fiscal year 2013 (October 1, 2012 through September 30, 2013): Fall protection, construction (29 CFR 1926.501) [related OSHA Safety and Health Topics page] Hazard communication standard, general industry (29 CFR 1910.1200) [related OSHA Safety and Health Topics page] Scaffolding, general requirements, construction (29 CFR…...

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Smoking at Fuel Pump is NOT a good idea (Video)

Many of us got a “chuckle” from the 2013 Photo of the Week #42 (Smoking & Flammables) but here is proof it is NOT a laughing matter.  We continue to see people who seem to forget that gasoline is a highly flammable liquid and that ignition sources like matches, lighters and lit smoking materials are a…...

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EPA RMP Citations @ explosives facility (NH3, H2SO4 (and SO3), HNO3, )

On or about March 30-April 1, 2010, EPA conducted an inspection at one facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. On or about September 27-29, 2010, EPA conducted another inspection of the business but at another facility in a different location to determine compliance with Section 112(r)…...

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EPA RMP Citations @ speciality heat treating facility (NH3 and $6K)

On October 15, 2012 EPA conducted a compliance inspection of a specialty steel treating business (“Facility”) to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the October 15, 2012 inspection and documents submitted by Respondent,…...

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It is Lockout OR tagout… NOT BOTH

Here we sit, ending the year 2013, 20+ years after OSHA promulgated its Control of Hazardous Energy (e.g., Lockout/Tagout) standard. Yet, we still see so much confusion regarding this safety-critical standard. We get so much resistance on some of the most basic requirements of LOTO that I thought it would be helpful to dispel two…...

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What is it? Hint: Think piping RAGAGEP

Look closely… and what do you see?  Think about your piping RAGAGEP(s) for pressurized piping such as ASME B31.3 or .5.  Answer… What we are seeing is a piece of welded pipe that was being installed in an Ammonia Refrigeration process.  As REQUIRED by ASME B31.5, Section 527.5… 527.5 Qualification Records The employer shall maintain copies…...

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HAZCOM Training Modules from MI-OSHA

We are now down to less than 30 days to have our training completed on Labels and SDS’s.  Here is yet another state OSHA Plan that has gone out of its way to produce some excellent GHS HAZCOM presentations.  This Hazard Communication Employee Training program has been divided into three modules for use as “toolbox”…...

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