Tag Archives: OSHA

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 , , , , , , , , | Leave a comment

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

Posted in Compliance, EPA, OSHA | Tagged , , , , | Leave a comment

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

Posted in Compliance, General Information, Inspections, NEP, OSHA | Tagged , , , | Leave a comment

Who is Certified / Qualified to Train Process Operators?

Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading

Posted in Compliance, EPA, Operator Training, OSHA | Tagged , , | Leave a comment

Misunderstanding MOC

Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading

Posted in Compliance, Good Engineering Practices, Management of Change | Tagged , , | Leave a comment

A little memo with some very big implications

  Memo of Understanding between the DOL and DOJ: The U.S. Department of Labor (DOL) and the U.S. Department of Justice (DOJ), recognizing the importance of ensuring the health and safety of America’s workforce, enter into this memorandum of understanding … Continue reading

Posted in Community Involvement, Compliance, OSHA | Tagged | Leave a comment

OSHA fines to rise 80%?

OSHA Defense Report says that the  “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” gives OSHA the green light to increase penalty amounts to catch up with cost of living adjustments since the last time OSHA’s civil penalties … Continue reading

Posted in Compliance, Culture, OSHA | Tagged , | Leave a comment

OSHA Memo on RAGAGEP

Link to OSHA publication – Highlights (underline) are mine. Note that they reference the CCPS again. The really good stuff is at the bottom in the notes to the inspectors.   MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY … Continue reading

Posted in Compliance, NEP, OSHA | Tagged , , , , | Leave a comment

Region 7 Ammonia Safety Day

If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading

Posted in Community Involvement, Compliance, CSB, EPA, Operator Training, OSHA | Tagged , , , , , | Leave a comment

Relief Systems – Understanding Design and Design Basis

In compliance audits all over the country, we’re finding that the requirements for documenting the relief systems are not being met in many PSM programs. How bad is the situation? About 1/3rd of the relief documentation we see shows that … Continue reading

Posted in Compliance, Good Engineering Practices | Tagged , , | Leave a comment