Tag Archives: EPA

Refresher Training

Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading

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Website Availability of Non-OCA RMP Data

Email from the EPA: . As you know, EPA regulates certain hazardous chemical facilities under 40 CFR Part 68 – known as the EPA Chemical Accident Prevention or Risk Management Plan (RMP) program.  EPA is aware that state and local … Continue reading

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PSM NEP Podcast

I spent about two hours in the recording studio today with Jeremy Williams of GCAP. You can listen to the first part of our conversation on the NEP at GCAPCoolCast.com I’ve spent the last three weeks at GCAP re-working the … Continue reading

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Tanner agrees to install $345,000 in ammonia leak detection systems

“While Tanner did take some actions to address the risks of an accidental release of ammonia at its facility in Rhode Island, Tanner failed to address the risk associated with the fact that its facility is not staffed except when … Continue reading

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Dairy SPCC exemption, Under-Ride Hazards

These two items are not PSM related but they are of interest to those of us who work in Dairies and Cold Storage distribution warehouses and they are important enough that they merit wider discussion. EPA Exempts Milk From Spill … Continue reading

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Dumping Ammonia Down the Drain? That’s a bad idea and it will cost you!

“On Jan. 24, 2008, an ARC technician was performing a service job that required the removal of all ammonia from the refrigeration system’s 1,683-gallon holding tank, Assistant U.S. Attorney Bill Morse said. After transferring most but not all of the … Continue reading

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Update your RMP at least Every 5 Years

EPA requires you to update your RMP at least every five years. It doesn’t take long to do at all if you haven’t changed much in the last five years. You’ll almost always find a little thing to change, even … Continue reading

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Garden City Ammonia Program PodCast

I recently had a long conversation with Craig Ward of Garden City Ammonia Program. He turned it into an episode for their GCAP Cool Cast. You can listen to the entire conversation here. As always – feedback is welcome.

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RAGAGEP: Just what is it?

RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practice. OSHA: OSHA 29 CFR 1910.119 (D)(3)(ii): “The employer shall document that equipment complies with recognized and generally accepted good engineering practices.” EPA: EPA 40 CFR 68.73 (d)(2): “Inspection and testing … Continue reading

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EPA settles with Pacific Seafood Group

EPA extracted a $35,000 penalty for not complying with the Emergency Planning and Community Right to Know Act. In the agreement, EPA alleges that Pacific Seafood failed to immediately notify emergency response entities after the ammonia release occurred and they failed … Continue reading

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