Bryan Haywood

How often do SCBA cylinders need to be “topped off” to ensure they stay above 90% full?

The amount of breathing air consumed during a monthly SCBA functional test (often referred to as the “monthly inspection” or “flow test”) varies slightly by manufacturer and the specific depth of your inspection/testing SOP. However, for a standard 30-minute/45-cubic-foot cylinder, you can estimate the usage based on the required NFPA 1852 checks…. Membership Required You...

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Gemini+ answers the mystery behind the 2216 psig cylinder pressure

A question I have asked for years, starting back in the late 1980’s when I began wearing SCBAs. I have asked this question to dozens, maybe hundreds of people, way smarter than me, and everyone was stumped. So today I had a lengthy discussion on SCBAs and the question was asked of me again. So…...

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When you see it… Flange Jumpers for Flammable Liquid & Combustible Dusts Piping

Many may be familiar with “flange jumpers,” or some may call them “bonding jumpers,” that are used to ensure a continuity to ground across a flange with gaskets that act as “insulators”, such as PTFE gaskets. During a recent walkdown of a flammable liquids process, I came across this “jumper”. Design called for “jumpers” on…...

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EPA RMP/EPCRA citations @ Refinery (HF & $270K)

Respondent operated a facility (the “Facility”) that refines petroleum products using a hydrofluoric acid alkylation process. On June 2-3, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during…...

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EPA RMP/EPCRA citations @ ethanol manufacturing facility (Flammables & $169K)

Respondent is the owner and operator of an ethanol manufacturing facility handling a mixture of hydrocarbon liquids, butane, isopentane, and pentane. Pursuant to 40 C.F.R. § 68.115(b)(2)(i), the entire weight of the mixture shall be treated as the regulated substance when the concentration of each of the regulated substances is 1% or greater by weight…...

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EPA RMP/EPCRA citations @ food facility (NH3 & $262K)

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to package, refrigerate, store, and ship cherries and grapes.On September 16, 2021, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the…...

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What drives the need for Hydrostatic Relief Valves on piping?

Yes, I am still on this horse! As I discussed last month, there are a number of chemicals that specifically REQUIRE HRVs on liquid piping. Those are chemicals like NH3, Cl2, and LPG, to name the top three (3). But I have recently read a root cause analysis in which a flammable-liquid piping flange leaked,…...

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Chemical hoses aren’t the only hoses needing annual inspection and pressure testing!

I have written over a dozen posts explaining the code requirements for annual inspection/testing of our chemical hoses. But in the world of PSM/RMP, there is another hose that requires annual inspection and testing… The primary standard requiring fire hose to be service-tested annually is NFPA 1962, Standard for the Care, Use, Inspection, Service Testing,…...

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Another graphic depicting ZES = 0, not 0.1 psig

I have been having fun using AI to help me create training images. I love doing LOTO training, and I am always challenged on just how little energy it takes to be “hazardous” and how even 0.1 psig can be lethal. (as shown below)… Membership Required You must be a member to access this content.View...

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The math of a “Small” Vacuum

A couple of years ago, in a PHA, I came across a scenario where a “capture device” had quite “the pull” on several small tanks that were NOT rated for a vacuum. As usual, my inquiry was met with the old “this is the way all the other plants were built and they have not…...

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NTSB Updates NaOH Truck Explosoin (5/8/26)

On April 7, 2026, about 7:15 a.m. local time, a DOT 407 AL (aluminum) cargo tank, owned and operated by Brenntag, carrying about 1,100 gallons of Sodium Hydroxide Solution (UN1824), exploded at a facility in Mooresville, North Carolina. The driver of the semi-tractor-trailer to which the cargo tank was attached was killed in the explosion…....

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