Category Archives: Compliance

Regulatory Compliance

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

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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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OSHA replaces the ChemNEP inspection protocol

Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading

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Trump Regulatory Freeze likely to delay EPA RMP Updates

According to a memo from Reince Priebus ( Regulatory Freeze Memo 012017 ) the EPA RMP updates are likely to be delayed: With respect to regulations that have been published in the OFR but have not taken effect, as permitted by applicable law, … Continue reading

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2017 SOP Template Updates

The SOP reference element guideline and RESOP/ROSOP reference  templates have been updated for 2017. The changes are basically broken into two groups: Continuous Improvement and IIAR 7. Continuous Improvement: As always, there are a lot of little change suggestions that … Continue reading

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Merry Christmas from the EPA!

Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … 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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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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