Bryan Haywood

When to Revise Off-Site Consequence Analysis (EPA FAQ)

The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA?… Membership Required You must be a member...

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Are Mechanical Controls Considered Administrative Controls? (EMP RMP OCAs)

For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical…...

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Worst-case Release Scenario for Separate, Interconnected Vessels (EPA FAQ)

Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two (2) separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? … Membership Required You must be a member to access this content.View...

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Worst-case “quantity released” reporting for a mixture (EPA FAQ)

In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic…...

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Ammonia (concentration 20% or greater) and Ammonia (anhydrous) Alternative Release Scenarios (EPA FAQ)

Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one (1) alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous) on site above their…...

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NFPA’s Tentative Interim Amendment (TIA) 27-1 – 2027 Edition of NFPA 30

Tentative Interim Amendment (TIA) 27-1 refers to a significant update to the 2027 Edition of NFPA 30: Flammable and Combustible Liquids Code. Issued on April 15, 2026, with an effective date of May 5, 2026, this TIA (Log #1886) was processed by the Technical Committee on Flammable and Combustible Liquids to address safety gaps regarding…...

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What is a Hierarchy of Hazard Control Analysis (HCA)?

Under Cal/OSHA’s Process Safety Management (PSM) standards (specifically Title 8 §5189.1 for refineries and §5110.16 for other facilities), the Hierarchy of Hazard Control Analysis (HCA) is a formal, documented requirement that goes significantly beyond the traditional OSHA “inverted pyramid.” While standard safety protocols often treat the hierarchy as a suggestion, Cal/OSHA makes it a mandatory…...

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The CSB’s Fiscal Year 2026 Top Management Challenges

A new report from the EPA Office of Inspector General (May 6) highlighted that the U.S. Chemical Safety Board (CSB) is currently operating at only 40% board capacity (two out of five members), which restricts its ability to formally approve investigation reports and safety recommendations. The Clean Air Act Amendments of 1990 established that the…...

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Understanding OSHA’s Revised Heat National Emphasis Program (NEP)

The revised Heat National Emphasis Program (NEP), relaunched on April 10, 2026, represents a major shift in how OSHA handles heat-related enforcement. This isn’t just a renewal of the 2022 program; it is a full five-year directive (running through 2031) that gives inspectors more power to enter workplaces without a prior complaint. OSHA no longer…...

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Key Changes in the 2027 Edition of NFPA 30: Flammable and Combustible Liquids Code

The 2027 edition of NFPA 30 introduces significant structural and technical updates designed to improve clarity, streamline protection requirements, and integrate emerging safety technologies. Here are the primary changes professionals need to know…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Key Changes to the 2027 Edition of NFPA 70E (1 BIG change)

I do some shock-prevention training for electrical work (Gloves, Meters, LOTO, etc.), but I leave the big stuff like arc flash to those better qualified than me. But as safety pros, we have to stay informed of changes to this world-class standard. We see some crazy situations in our audits and assessments regarding electrical installations…...

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