Category Archives: General Information

General Information

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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What you need to know about Repeat Citations

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading

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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

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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

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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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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

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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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DHS CFATS Top-Screen Update

It looks like the DHS has finally got around to updating their Top-Screen program. Below is the email from them: ——————————————————————————– Subject: Enhanced CFATS Risk-Assessment Methodology and Upcoming Requirement to Submit CFATS Top-Screen From: “cfatsupdate” <cfatsupdate@hq.dhs.gov> Date: Tue, August 30, … 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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Change is coming to the Industrial Refrigeration world…

I have seen the future and it is going to mean some very large changes for the Industrial Refrigeration industry. As always, I want to talk about something else, before I get to my point… I want to talk about … Continue reading

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