Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Management Of Change (MOC) for Personnel

In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading

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Outsourcing your Contractor Selection Process – Can it be done?

Over the past few years we’ve seen an increase in the number of companies that use a 3rd party service to qualify their contractors. Often, these services screen the prospective contractor for their safety record / programs, insurance history / … Continue reading

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Updated RMP Rule likely delayed until at least 2019!

I’ve delayed updating the templates that reflect the proposed EPA RMP changes for several reasons. Our patience has been well-rewarded: The EPA has proposed to further delay the effective date to February 19, 2019. This action would allow the Agency time … Continue reading

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Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP

You may have recently heard a headline that OSHA is losing their right to cite you for something that happened more than six months ago. I’ve heard a disturbing amount of people tell me that this means that many PSM issues … Continue reading

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How to get Willful OSHA Citations & Fines

The incident we are discussing today is from a recent ruling in the United States Court of Appeals, Seventh Circuit where they recently denied a petition for review in the case of “DANA CONTAINER, INC. v. SECRETARY OF LABOR.” While this … Continue reading

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Authorized Personnel Only

Found a funny sign on the internet and someone wanted it for their very own. Here’s my version of the traditional Machinery Room Door Sign: Update: At the request of a friend, here’s another:    

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Why does my PSM program make me review the PHA during any equipment/facility MOC?

Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading

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What questions should I expect during a ChemNEP inspection?

A friend in the industry recently went through an OSHA ChemNEP inspection on their NH3 Refrigeration System. Over the years, I’ve had the pleasure of working with many of their team members and have audited several of their facilities. They … Continue reading

Posted in Compliance, General Information, Inspections, Mechanical Integrity, NEP, Operator Training, OSHA, SOP Development, Training | Tagged , , , , , , , , | Leave a comment

Update: Congressional Review Act & RMP Rule

The EPA’s RMP Rule update is NOT part of the initial 5 regulations that the House has decided to disapprove via the Congressional Review Act. (Bloomberg)   …and here it is! US Rep. Markwayne Mullin (R-Okla.) introduced Congressional Review Act … Continue reading

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While there are Executive Branch delays to the EPA’s new RMP updates, another possibility is that congress can use the Congressional Review Act to nullify the changes. This week, a group of associations joined in a letter requesting exactly that. Multi-Association … Continue reading

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