Monthly Archives: January 2017

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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