Category Archives: Mechanical Integrity

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

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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

Appeals Court upholds Contractor PSM Citations

A maintenance contractor that provides skilled labor to perform skilled labor, electrical and mechanical work was cited by OSHA for violations of the PSM standard after their employee was injured by a chemical release. OSHA threw the book at them … Continue reading

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IRC releases their Mechanical Integrity Guidebook

I’ve had my copy for a few months and think the IRC has done a fantastic job with this book. Here is the press-release: The IRC is pleased to announce the immediate availability of a new guidebook titled: Principles and … Continue reading

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What’s the deal with Valve torque?

A common question I get is whether or not flanged and bonneted valves need to be torqued when they are installed. Unfortunately, many of these questions are due to OSHA citations – Ideally you want to answer this question BEFORE the … Continue reading

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What does OSHA think is the biggest concern in ammonia refrigeration components?

I read a disturbing amount of OSHA documents through FOIA requests for research. About 99% of the stuff I read is pretty useless or already known to me from previous reading, but occasionally you come across something that wasn’t redacted … Continue reading

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Five Year Independent Full Inspection

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading

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Hansen Relief Valve Recall

If you use Hansen relief valves, this bulletin might be of use to you: . Hansen recently discovered that certain pressure relief valves sold to our customers for industrial use from February 16, 2011 to April 4, 2013 are more … Continue reading

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Pressure Relief Valves – The Five Year Replacement Interval

There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading

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Torque Wrenches for Ammonia refrigeration valves

Yes, it really has come to this. Let’s start with a single citation… What equipment could this citation be concerning? Take a look at the compliance officer’s narrative: The officer went on to say in the OSHA 1-B Inspection worksheet: … Continue reading

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