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Category Archives: Compliance
Outsourcing your Contractor Selection Process – Can it be done?
Over the past few years we’ve seen an increase in the number of companies that use a 3rd party service to qualify their contractors. Often, these services screen the prospective contractor for their safety record / programs, insurance history / … Continue reading
Posted in Compliance, Contractors
Tagged Contractors, PSM, RMP
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Updated RMP Rule likely delayed until at least 2019!
I’ve delayed updating the templates that reflect the proposed EPA RMP changes for several reasons. Our patience has been well-rewarded: The EPA has proposed to further delay the effective date to February 19, 2019. This action would allow the Agency time … Continue reading
Posted in Compliance, EPA
Tagged EPA, RMP
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Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
You may have recently heard a headline that OSHA is losing their right to cite you for something that happened more than six months ago. I’ve heard a disturbing amount of people tell me that this means that many PSM issues … Continue reading
Posted in Compliance, Inspections, OSHA
Tagged EPA, Fines, OSHA, PSM, RMP
Comments Off on Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
How to get Willful OSHA Citations & Fines
The incident we are discussing today is from a recent ruling in the United States Court of Appeals, Seventh Circuit where they recently denied a petition for review in the case of “DANA CONTAINER, INC. v. SECRETARY OF LABOR.” While this … Continue reading
Posted in Community Involvement, Compliance, OSHA
Tagged Incidents, OSHA
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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
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RMP
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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
Posted in Compliance, General Information, Inspections, Mechanical Integrity, NEP, Operator Training, OSHA, SOP Development, Training
Tagged Fines, Lessons Learned, Mechanical Integrity, NEP, Operator Training, OSHA, PSM, RAGAGEP, Standardization
Comments Off on What questions should I expect during a ChemNEP inspection?
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
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
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
Posted in Compliance, EPA
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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
Posted in Compliance, Good Engineering Practices, SOP Development, Standardization
Tagged RAGAGEP, SOP, Standardization
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