Bryan Haywood

Understanding OSHA’s HAZWOPER standard for Emergency Response

OSHA’s standards for general industry and the construction industry on hazardous waste operations and emergency response (29 CFR 1910.120 or 29 CFR 1926.65) cover all employees involved in: Clean-up operations of hazardous substances at uncontrolled hazardous waste sites required by Federal, state, local or other governments; Corrective actions involving clean-up procedures at sites covered by […]

Nurse Tank Safety and Compliance Advisory letter (2008 Reminder)

  Based on eight (8) recent enforcement investigations, conducted by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Hazardous Materials Enforcement (OHME), this letter is intended to notify the industry of serious safety problems and non-compliance issues regarding the maintenance, filling, transport and use of nurse tanks in anhydrous

An overview of Human Performance Management

Human factors are concerned with optimizing human performance in all tasks and in major hazard workplaces; the primary intention is to achieve safe performance. These high-risk workplaces should have conducted risk assessments and established a range of controls to prevent major accidents. Still, they should also focus on human performance issues to eliminate or reduce

Don’t Let Safety Take a Holiday! (Poem)

Twelve days before the Holidays,  My Safety Team said to me,     No cuts or lacerations  Wear your PPE,     No slips, trips or falls  Watch where you put your feet,    No strains, aches or pains  Use your safe lifting techniques,     Watch your head and keep it safe  Always be aware of overhead

National Board Inspection Code vs. API 510

This article discusses how a facility would need to get one of its coded pressure vessels repaired, altered, or re-rated. The article will cover pertinent code and jurisdiction requirements and the differences among the American Society of Mechanical Engineers (ASME) Code, the National Board Inspection Code (NBC), and American Petroleum Institute (API) requirements, as well

Process Hazards Analysis Techniques (Methodolgies, Resources, and Time)

A Process Hazard(s) Analysis is a thorough, orderly, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The facility shall perform a process hazard analysis on all processes covered by EPA’s RMP rule and/or OSHA’s PSM standard. The process hazard analysis methodology selected must be appropriate to the

Breaking down 1910.120(q)(2) Written ERP requirements

HAZWOPER EMERGENCY RESPONSE PLAN DEVELOPMENT GUIDELINES(Elements of an Emergency Response Plan)1910.120(q)(2)  (i)  Pre-emergency Planning and Coordination with outside parties Facilities are required in the Superfund Amendments and Reauthorization Act (SARA) title III to coordinate their activities with outside response organizations and emergency response organizations. The emergency response plan (ERP) MUST address coordination with outside emergency

What is Error Management? (Reason, 1997)

Error Management (EM) has two (2) components: error reduction and error containment Error reduction comprises measures designed to limit the occurrence of errors. Since this will never be wholly successful, we also need error containment measures designed to limit the adverse consequences of those errors that still occur. At this general level, EM is indistinguishable

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