Bryan Haywood

A look at OSHA’s Construction Standard on Permit-Required Confined Spaces

This standard describes minimum practices and procedures to prevent worker exposure to dangerous safety and health hazards in a confined space. It also recognizes the dynamic character of confined spaces as they occur in construction. Thus, the standard and our enforcement focus on the employer’s whole program as conceived, documented and implemented as a primary…...

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ASME and Hot Bolting and Half Bolting Procedures

First, let’s define what this article is all about. Has your facility ever had a leaking flange?  Just a tiny drip of liquid or a small release of gas? What is the most common response to this leaky flange?  Someone goes out and tightens the flange bolts to stop the leak. This practice is done…...

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Re-Submitting your RMP

RMPs MUST be updated at least once EVERY five (5) years. Owners and operators responsible for RMP implementation should review the factsheet A Checklist for Submitting your Risk Management Plan (pdf). This factsheet provides a checklist to consider in updating and resubmitting RMPs. Use EPA’s RMP*eSubmit for your resubmissions. For additional information see the RMP*eSubmit Users’…...

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RMP Facilities in the United States as of December 2009

Under the Clean Air Act, Section 112(r), the EPA established a program requiring facilities possessing greater than certain threshold quantities of 140 chemicals to provide risk management plans to the EPA.1  As part of this reporting requirement, facilities are required to determine the worst-case scenario release from a single chemical process, using EPA criteria and guidelines.2 Facilities…...

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Establishing a Reporting Culture (Psychological Safety)

It cannot be assumed that workers will naturally begin to report problems, errors, and near misses once a just environment is in place. There are a number of organizational as well as psychological barriers that must be hurdled before a reporting culture can be put in place.   The first barrier to overcome is… Membership Required...

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Externally vs. Internally illuminated EXIT signs

In older facilities, we see illumination for an exit sign coming from an external source.  Section 1013.6 of the IBC regulates the graphics, illumination, and emergency power supply for such signs. Although no particular color is specified for exit signs, it is REQUIRED that the color and design of the signs, the lettering, the arrows,…...

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Dr. Dekker’s “Two views on Human Error”

Dr. Sidney Dekker (Ph.D. in Cognitive Systems Engineering) states there are basically two (2) ways of looking at human error. In this article, I share with you, the first view, which could be called “the bad apple theory“. It maintains that:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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Reason’s 3 C’s

Three (3) ingredients are vital for driving the safety engine, all of them the province of top management or what the organizational theorist, Mintzberg, has termed the strategic apex of the system. These driving forces are: commitment, competence and cognizance Reason’s three C’s…. Membership Required You must be a member to access this content.View Membership...

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Verifying my “ground” has less than 10 ohms resistance

Verifying that grounding and bonding systems meet a specific resistance threshold—such as the common 10 ohms target for flammable liquid processes—requires a systematic approach to ensure both accuracy and technician safety. The following procedure outlines the steps for performing a static ground-resistance test using a dedicated ground-resistance tester (Ohmmeter). This procedure applies to the periodic…...

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De-enerizing Stored Energies

Take any of the following steps below that may be necessary to guard against stored energy(s) left in the equipment after it has been shut down and isolated from its energy source(s)…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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A reverse look at Facility Siting and Change Management

An older post, with updates…Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities.  As with all of the PSM elements, many of us took this new focus as a learning opportunity.  We had all done something we called “facility siting”…...

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