Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Worksite Posters

Head on over to RCE-Chill to see our latest worksite posters.

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Yet another update on the RMP Updates!

Today, EPA’s Administrator, E. Scott Pruitt, signed a new proposed rule, further changing the Obama-era EPA’s proposed changes and the EPA is submitting that for publication in the Federal Register (FR). Basically, it outlines two proposals for the Obama-era EPA’s … Continue reading

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Learning from Failure

“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading

Posted in Culture, General Information, Good Engineering Practices, Incidents, OSHA, System Optimization | Tagged , , , , , | Leave a comment

What you need to know about Repeat Citations

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading

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General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

Several times a year I get a phone call or an email from a client that wants to lower the NH3 inventory below the federal 10,000lb threshold so they are no longer subject to the PSM/RMP rules. It’s a conversation … Continue reading

Posted in Community Involvement, Compliance, General Duty, Good Engineering Practices | Tagged , , , , | Leave a comment

IIAR 7 update now open for Public Review

November 10th, 2017 To: IIAR Members Re: First (1st) Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems. A first (1st) public review of draft standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems is now … Continue reading

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RAGAGEP Hierarchy in Application – A worked example

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading

Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA | Tagged , , , , , | Leave a comment

PHA Worksheets Template updated

The Template What-If / Checklist worksheet used to guide PHA Studies has been modified. The Identification and Review of Past Incidents section has been renumbered with some new questions concerning the performance of the Incident Investigation element added before the example / … Continue reading

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Why we changed our element “Guidelines” to be called “Written Plans”

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading

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What training does my refrigeration operator need?

Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation. Understanding the requirements of PSM/RMP training for Operators The Training element in PSM (1910.119(g)) and … Continue reading

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