Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Yeah, but No – Compliance vs. Safety

Often, compliance and safety go hand-in-hand. This leads us to believe they are the same thing. Occasionally they are not; and when that’s the case, it is our duty to place SAFETY above Compliance. Relief Piping Termination – A worked … Continue reading

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IIAR 2-2014, Addendum A Third Public Review

The IIAR has announced a 3rd Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems. This brings some interesting changes to IIAR 2 . Two of these proposed changes are : Clearing up the … Continue reading

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EPA RMP update “Delay” rule vacated by DC District Court

EPA retains authority under Section 7412(r)(7) to substantively amend the programmatic requirements of the Chemical Disaster Rule, and pursuant to that authority, revise its effective and compliance dates, subject to arbitrary and capricious review. . . . the agency must … Continue reading

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Properly Addressing Findings / Recommendations

Process Safety managers are often buried under a torrent of Findings and Recommendations from PSM/RMP elements such as Employee Participation (EP), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), Incident Investigations (II), and Compliance Audits (CA). In compliance audits over … Continue reading

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What can we learn from the Fernie Ammonia fatalities?

The October 17th, 2017 Ammonia release in Fernie, BC resulted in three fatalities: On October 16, 2017, the curling brine chiller at the Fernie Memorial Arena was put back into operation after a seasonal shutdown. During the shutdown and seasonal … Continue reading

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Is a condenser change a Replacement in Kind?

The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading

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IIAR 6 Public Review #3

Make your opinion known BEFORE the changes go final! IIAR 6 continues its development. This document will replace IIAR Bulletin 110 (among others) and will be very important. The current review only lists changes since Public Review #2. To: IIAR Members … Continue reading

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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

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