Bryan Haywood

OSHA recordkeeping when you have no recordables for the year

Question: If an employer has no recordable cases for the year, is an OSHA 300-A Annual Summary still required to be completed, certified, and posted? Answer: Yes. After the end of the year, employers must review the Log to verify its accuracy, summarize the 300 Log information on the 300A summary form, and certify the…...

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HF flange fails and results in fatality

At 11:50 a.m. on October 21, 2021, an employee, 51, was assisting his coworkers in troubleshooting the fresh hydrogen fluoride (HF) system to the vaporizer. The employee was looking at an actuator that was across from a whisping flange when the flange failed, and hydrogen fluoride was sprayed on him. The employee screamed, and his…...

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EPA RMP citations @ water treatment plant (Cl2 & $13,500)

This is what drives me crazy! A water treatment plant that falls under EPA’s RMP and yet has made zero effort to comply with the standard gets 11 citations, and the fine was $13,500, which was “adjusted” down to $10,800. This is a PUBLIC entity handling Chlorine (Cl2) in a densely populated area (see Google…...

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Line/Equipment Opening Gone Bad (Hydrocarbon)

A hydrocarbon leak caused the fire at a California refinery on February 1, 2025. The leak occurred while two workers were opening equipment for maintenance…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The role of “Skilled Support Personnel” in an Emergency Response

It has been reported that OSHA issued a citation to a Railroad ( a subsidiary of one of the six Class 1 RR’s) after an employee experienced respiratory distress when they were told to wear a self-contained breathing apparatus during the process of disconnecting train cars at the derailment site. The employee had not been…...

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Safety Thought of the Week… We have to STOP saying, “You can’t fix stupid” (Dr. Todd Conklin)

I hate the phrase, “you can’t fix stupid.” It is offensive and mean; most importantly, that phrase is just wrong. Stop saying it. Stop using this phrase right now. “You can’t fix stupid” is serving you and your organization poorly. It colors your thinking, it makes you stop investigations too early, it sounds like something…...

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Criminal charges could apply to inspection failure before fatal Louisville plant explosion, official says

The Kentucky agency that oversees boiler safety claims the plant operated a vessel that exploded without a proper inspection permit. The Kentucky Department of Housing, Buildings and Construction found that the cooker that exploded was installed without a required permit that would have triggered a state inspection. https://www.wdrb.com/wdrb-investigates/criminal-charges-could-apply-to-inspection-failure-before-fatal-louisville-plant-explosion-official-says/article_704fb426-e566-11ef-a8a2-87af2efe4771.html… Membership Required You must be a member...

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The DO’s and Don’ts of Pressure and Leak Testing Piping (ASME B31)

B31.3 requires that each piping system be leak-tested to ensure tightness prior to initial operation [¶345.1]. B31 imposes certain restrictions on the types of leak tests which may be used, some general requirements for conducting leak tests, some preparation requirements for leak tests, some specific requirements for each type of leak test, and some record…...

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Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502

February 5, 2025 MEMORANDUM FOR: REGIONAL ADMINISTRATORS STATE PLAN DESIGNEES THROUGH: SCOTT C. KETCHAM, Deputy Assistant Secretary FROM: ERIN P. GILMORE, Acting Director Directorate of Enforcement Programs SUBJECT: Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502 On June 21, 2021, OSHA adopted a Healthcare Emergency Temporary standard (Healthcare ETS) protecting…...

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Process Safety Leadership Assessment (UK’s HSE Energy Division)

Failures in effective process safety leadership/process safety management can be linked to historical Major Accident Hazard (MAH) events such as Piper Alpha, Buncefield and Texas City amongst others. In 2018, HSE flagged concerns about the offshore industry regarding stagnating safety performance and challenged the industry to respond, leading to the adoption of the Principles of…...

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PSIG may be the most misunderstood fundamental property in process safety

I am always amazed at the lack of a basic understanding of atmospheric pressure and process pressures/vacuums. My Intermediate 3-Day PS course and my Advanced 5-Day PS course have a single slide, and every time, I find I have to spend an hour explaining to the class what PSIG is and how it’s different from…...

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