Bryan Haywood

EPA RMP Citations @ food facility (NH3 & $93K)

Respondent owns and operates a processed cheese manufacturing facility. On or about December 16-18, 2024, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with 40 C.F.R. Part 68 (the “Subject Compliance Inspection”). Information gathered during the EPA’s Inspection revealed that the Respondent had greater than 10,000 pounds of anhydrous ammonia

OSHA has proposed $3.5M in fines for violations by 3 employers during a Houston facility chemical spill response

OSHA has proposed more than $3.5 million in fines against three (3) companies after federal inspectors determined they failed to protect workers during post-emergency response cleanup after a chemical spill at an industrial facility in Channelview. OSHA initiated three (3) inspections following a Dec. 27, 2025, sulfuric acid spill that resulted in multiple employee injuries.

OSHA and NFPA have aligned on “the potential” for a HAZ ATM within a PRCS, but would you “reclassify” the space under their guidance?

Both OSHA and NFPA state that if the pipe does NOT terminate within the space, the pipe does NOT have to be evacuated to consider the contents of the pipe a “potential” to generate a HAZ ATM. In a recent OSHA LOI, OSHA used several thresholds that the employer should/must use in its evaluation of

Risk of compromised pressure relief on cryogenic tank containers

The purpose of this Safety Alert is to highlight the risks associated with compromised pressure relief circuits on Cryogenic Tank Containers. Cryogenic Tank Containers are commonly used for transportation and/or storage of cryogenic liquids, including, but not limited to, Nitrogen, Oxygen, and Argon. A large explosion occurred at a cryogenic gas transport depot in Tamworth,

Almost 50% of serious HAZMAT transportation incidents occur during loading and unloading operations

The transfer of hazardous materials from a cargo-tank motor vehicle to fixed-site storage poses a critical vulnerability in chemical handling. While high-speed highway collisions capture more attention, the Pipeline and Hazardous Materials Safety Administration (PHMSA) estimates that roughly 25% to 50% of serious HAZMAT transportation incidents actually occur during loading and unloading operations. These accidents

EPA RMP Citations @ food facility (NH3 & $130K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia for cooling to pack, process, and distribute its food products. On July 11, 2024, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, the Emergency

EPA RMP Citations @ food facility (NH3 & $106K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia to manufacture and produce citrus products, to develop frozen fruit concentrate, juice, oils, and pulps from oranges, lemons, and grapefruits. On October 24, 2023, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental

What is the Welding Certification actually evaluating when the welding will be done by a pipe welding machine?

When we introduce a pipe welding machine (such as an orbital welder) into the fabrication process, the focus of the certification fundamentally shifts. Under industry codes such as ASME Section IX, the individual operating the equipment is no longer classified as a “Welder”; they are designated as a “Welding Operator.” Because the machine handles the

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