Category Archives: NEP

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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When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?

First off: What is a Car-Seal program and what does it do?  A Car-Seal program is designed, implemented and managed to ensure that safety-critical valves within the covered process are maintained in their safety-critical position / setting during normal system … Continue reading

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OSHA increases fine amounts by 78%!

In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. The Department of Labor is adjusting penalties for its agencies, including the Occupational Safety and Health Administration (OSHA). OSHA’s maximum penalties, which … Continue reading

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OSHA Memo on RAGAGEP

Link to OSHA publication – Highlights (underline) are mine. Note that they reference the CCPS again. The really good stuff is at the bottom in the notes to the inspectors.   MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY … Continue reading

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OSHA is going to have a field day in 2016

The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading

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OSHA to revise Palmer guidance on Hydrostatic Trapping

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading

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OSHA to focus on difficult inspections (like PSM) in 2014

Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading

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The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading

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Interesting Times

A wise man once said that it was a curse if someone said to you: “May you live in interesting times.” EXECUTIVE ORDER – – – – – – – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested … 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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