Bryan Haywood

Flammable refrigerant gases – position paper (Government of Western Australia, 3/2025)

This paper concerns refrigerant gases classified as Division 2.1 flammable gases under the Australian Dangerous Goods Code (ADG Code) or classified as Flammable Gas Category 1 using the Globally Harmonized System (GHS). It covers general work health and safety/occupational health and safety (WHS/OHS) duties, however, readers should check their legislative responsibilities at the state/territory and…...

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Gasket rupture at LPG processing facility results in leak

On 6 December 2016, an operator at a liquefied petroleum gas (LPG) processing facility heard a loud noise coming from an area of the plant during start-up, following major maintenance on the process. The operator identified that high-pressure, flammable gas was being released to the atmosphere from a point beneath the insulation of process equipment…....

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Regeneration gas heater catastrophic failure

In April 2024, a regeneration gas heater ruptured at a gas processing plant due to an overheated electrically heated regeneration vessel. Regeneration gas heaters are commonly used in the regeneration of molecular sieve dehydrators with the recirculation of dried natural gas heated to 250 degrees Celsius throughout adehydrating purge cycle. The initiation of manual operating…...

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EWP causes NH3 leak leading to serious respiratory injuries

A worker was exposed to NH3 while working next to a live refrigeration unit. The worker was working from an elevating work platform (EWP) to install a partition wall in a large refrigerated space. The EWP was in close proximity to a chiller unit that was operating during the work. The EWP knocked a valve…...

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Virtue Signaling erodes trust and credibility

If the company leadership team, including the Board of Directors (BOD), cannot explicitly state what they want from the EHS team and what level of performance they wish to achieve, then we are being set up to fail. I am amazed at how a leadership team will claim a multi-million-dollar project was a “safety project”…...

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Can the company parking lot offer clues as to what we are walking into?

Recently, I visited an old client after a long absence. As I pulled into the parking lot, I immediately noticed the upgrade to the freshly paved and striped parking lot. My last visit, years earlier, I ended up parking in a crater in a gravel lot that some smaller cars would not have been able…...

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Criticality Accidents: Administrative Failure (April 1975, Rensselaer Engineer)

A long-time friend (Bill Conlon, President at Pintail Power) and a remarkable engineer (not officially an SE- LOL) shared with me his first published article, from April 1975, in which he argued against relying on Administrative Controls and instead advocated for safety through design as the way to manage risks. Now, for a man who…...

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EPA RMP Citations @ prepared foods processing plant (NH3 & $68K w/ $48K SEP)

Respondent owns and operates a prepared foods processing plant located within one mile of a residential area, an elementary school, a pond, a river, and many businesses. Respondent uses anhydrous ammonia in a refrigeration process,” as defined by 40 C.F.R. § 68.3, in a series of interconnected pipes and vessels at the Facility (the “Process”)…....

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EPA RMP Citations @ chemical manufacturing facility (Anhy NH3/>20% NH3 & $40K w/ $157K SEP)

Respondent operates a chemical manufacturing facility which has on-site for use, 25,299,678 pounds of anhydrous ammonia and 355,094 pounds of ammonia (concentration 20% or greater). Respondent has two RMProgram level 3 covered processes, that store or otherwise use anhydrous ammonia and ammonia (concentration 20% or greater) in amounts exceeding their applicable thresholds of 10,000 pounds…...

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CSB Issues Final Report on Toxic HF Incidents at Geismar, Louisiana Facility

Today, the CSB released its final report addressing three (3) serious chemical incidents involving toxic hydrogen fluoride (HF) at a facility in Geismar, Louisiana. The incidents occurred over a period of less than three years, from October 2021 to June 2024, and reveal systemic safety failures at the facility. These incidents were LOPC events, two…...

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These safety strategies work – But are you using them? (WA-OSHA)

One of the most effective ways to reduce the risk of injury while operating machines is to use what’s called the Hierarchy of Controls method. It ranks the ways to reduce risks from most effective to least effective. Often, you’ll need to combine control methods to best protect workers…. Membership Required You must be a member to...

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Defining RAGAGEPs for Process Safety Management (Rand Study)

Process safety management (PSM) is a suite of risk management elements designed to minimize the risk of accidents associated with industrial processes using highly hazardous materials. The California Division of Occupational Safety and Health (Cal/OSHA) PSM regulation requires that process equipment and equipment inspection and testing adhere to recognized and generally accepted good engineering practices…...

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