Bryan Haywood

EPA RMP Citations @ food plant (NH3 & $37K)

Respondent is the owner and operator of a facility. On September 1, 2024, an incident at the Facility resulted in an accidental release. EPA requested follow-up information, and Respondent provided a response on May 27, 2025, regarding the Incident and Respondent’s compliance with Section 112(r) ofthe CAA and 40 C.F.R. Part 68. Based on the…...

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Managing inventory of our HHC/EHS during emergencies

I ALWAYS encourage clients to be able to MANAGE their inventory when something goes wrong. Many have heeded my advice, and when they have a leak on a tank, they simply transfer the hazardous material to their “emergency tank,” or they have set their maximum levels in other tanks so they have spare capacity on…...

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Catastrophic low-water steam explosion (Boiler @ Food Plant 2021)

Damage description: Significant damage to the boiler room and all adjoining walls/rooms and area. Extensive damage to the west wall of the plant on Acton Pl. through the street. Damage was also noted to the adjacent building located at 390 E. King St. This complex housed several retail establishments. Damage was also noted to several…...

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Defining and Quantifying “incidental releases” and ones requiring an “emergency response”

This is a perfect (and sad) example of why releases of hazardous materials need to be DEFINED and QUANTIFIED so that personnel know their LIMITATIONS in responding to said releases. This exercise is part of our PRE-PLANNING, starting with using the Tier II forms we submit each year. Just understand, the Tier II forms are…...

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Isolating piping passing through a PRCS (OSHA LOI)

Well, it’s not often that I disagree with the OSHA technical team that writes LOIs, but this one is a MAJOR MISTAKE. I have debated this topic for 30 years and now my argument just got squashed by the agency. In their 2025 LOI, OSHA stated: If the employer’s evaluation of the space determines that…...

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Is this where we have arrived with Tech in the Safety Arena?!?! (Virtual PIT Evaluations?)

Background: 29 CFR 1910.178(l)(2)(iii) states: All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. Question #1: Can a person who has the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence, clarified…...

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Whether the respiratory protection medical evaluation may consider factors beyond respirator use (OSHA LOI)

OSHA answers two (2) Respiratory Protection Program questions: To what extent does OSHA’s Respiratory Protection standard, at 29 CFR § 1910.134(e), require that the PLHCP’s medical evaluation for respirator use include consideration of factors beyond respiratory protection that affect fitness to safely perform the expected job tasks while wearing a respirator?Is there a reasonable expectation…...

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Cell Phones in the workplace… just a bad idea!

On the evening of Christmas Eve, the Jackson Fire Department was alerted to a worker trapped inside a hopper at a local factory. Jackson Police Department, Jackson County EMS, Jackson Sheriff’s Office, Liberty Fire, and Jackson Fire units, including Jackson’s Rescue, Tower, and two engines, responded to the scene. The worker was attempting to retrieve…...

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Purging of gaseous hydrogen piping systems (IGC)

Where piping is to be opened for servicing, addition, or modification, the section to be worked on shall be isolated from the supply at the nearest convenient point, and the line pressure vented to the OUTDOORS. The remaining gas in this section of pipe shall be displaced with an inert gas. Prior to placing the…...

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CSB Issues Interim Safety Recommendations to U.S. Steel Clairton Coke Works Following Fatal Explosion

December 23, 2025, Washington, D.C. — The U.S. Chemical Safety and Hazard Investigation Board (CSB) today issued two interim safety recommendations in connection with the agency’s ongoing investigation into the August 11, 2025, fatal explosion at U.S. Steel’s Clairton Coke Works facility in Clairton, Pennsylvania. The explosion occurred when coke oven gas was released from…...

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