Category Archives: System Optimization

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

Posted in General Information, Standardization, System Optimization | Tagged , , | Leave a comment

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

Posted in Compliance, Management of Change, System Optimization | Tagged , , | Leave a comment

Pencil-Whipping can Kill

What is it? Pencil-whipping is when you complete a form, record, or document without having performed the implied work or without supporting data or evidence. Here are some common examples in NH3 refrigeration: Completing “word orders” without conducting the work … Continue reading

Posted in Compliance, Culture, General Information, Incidents, Inspections, Mechanical Integrity, Operator Training, System Optimization | Tagged , , , , | Leave a comment

Opinion: Why many Safety Programs fail to get results

The question that vexed me Over the past few years as a traveling PSM auditor I was exposed to hundreds of different safety programs. There were small, flat organizations with dozens of workers and large international conglomerates with thousands of … Continue reading

Posted in Compliance, Culture, System Optimization | Tagged , , , | Leave a comment

How should I FIX a PSM program?

This might be one of the most common questions we’re asked: How do I resurrect a PSM program that has been neglected? Our answer is that you should deal with these broken programs no differently than if you are starting a … Continue reading

Posted in General Information, Standardization, System Optimization | Tagged , , , | Leave a comment

First, Do no Harm!

The OSHA Law Blog has a nice post up called “Best Practices? Or Safety Run Amuck” about the unintended consequences that can occur when people rationalize their opinions as “Best Practice” without bothering to consult with the workers who are expected to … Continue reading

Posted in General Information, System Optimization | Tagged , , | Leave a comment

A few links I wanted to share…

First up, S.K. Energy Consulting: There are some simple to understand articles on Floating Head Pressure and Optimizing Defrost. Check out the articles archives which contain almost 80 newsletters going back several years. Very informational site that I am surprised I … Continue reading

Posted in Compliance, General Information, Standardization, System Optimization | Tagged , , , , , | Leave a comment

Refresher Training

Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading

Posted in Compliance, Operator Training, System Optimization | Tagged , , , , , , , | Leave a comment

A debate on Management of Change

Recently a group of safety yahoos got together to discuss a situation: You have a freezer with racking. The racking needs to be removed for XXXX reason. You hire a contractor to do the job. You evaluate and train the … Continue reading

Posted in Contractors, General Information, Incidents, Management of Change, NEP, Standardization, System Optimization | Tagged , , , , , | Leave a comment

PSM National Emphasis Program

If you aren’t familiar with the NEP (National Emphasis Program) currently going on in specific regions it would be well worth your time to get up to speed. Even if you have a top-notch program you’ve got a LOT of … Continue reading

Posted in Compliance, Good Engineering Practices, System Optimization | Tagged , , | Leave a comment