Bryan Haywood

Accident Investigation – Barrier Analysis

When analyzing barriers, investigators should first consider how the hazard and target could come together and what was in place or was required to keep them apart. Obvious physical barriers are those placed directly on the hazard (e.g., a guard on a grinding wheel); those placed between a hazard and target (e.g., a railing on […]

How does OSHA and EPA define “retail establishment” in regards to their “exemptions” from PSM/RMP

Retail facilities are exempted from PSM requirements.  At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In

EPA’s RMP and Program 3 NAICS #’s

As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how the EPA used the North American Industry Classification System (NAICS) to qualify a process

Testing and Inspection of Bonding/Grounding Systems

The proper installation of bonding and grounding systems is important in the protection of personnel and property. At the time of installation, a resistance test is needed to confirm electrical continuity to ground. Evaluating the maintenance requirements, the bonding and grounding system can be divided into three categories:

Am I required to have an Emergency Action Plan?

In the world of process safety, this is a no-brainer; but in normal manufacturing facilities, the answer can be quite confusing.  Bottom line… if your facility has a PSM-covered process (even an RMP Program 2 or 3 process) we are REQUIRED to have an EAP that complies with 1910.38.  But when we are not a

UPDATE – Calling the National Response Center

Who at your place of business calls the National Response Center after your business has experienced a chemical incident.  Not many people have ever had to call this center (luckily!) but if your business ever does have a “reportable release”  a call just like this one MUST BE MADE within 30 minutes after you have

Nuclear industry’s take on HOP’s Five Principles

Human Performance Improvement (HPI) is the systematic process of determining desired performance, continually monitoring performance, discovering and analyzing performance gaps, designing and developing effective interventions, implementing these interventions, and continually evaluating the results of improvement interventions within performance monitoring to ensure that the improvement process takes place.  The goal of excellence in human performance is

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