Tag Archives: PSM

Properly Addressing Findings / Recommendations

Process Safety managers are often buried under a torrent of Findings and Recommendations from PSM/RMP elements such as Employee Participation (EP), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), Incident Investigations (II), and Compliance Audits (CA). In compliance audits over … Continue reading

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What can we learn from the Fernie Ammonia fatalities?

The October 17th, 2017 Ammonia release in Fernie, BC resulted in three fatalities: On October 16, 2017, the curling brine chiller at the Fernie Memorial Arena was put back into operation after a seasonal shutdown. During the shutdown and seasonal … Continue reading

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Is a condenser change a Replacement in Kind?

The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading

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Learning from Failure

“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading

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What you need to know about Repeat Citations

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading

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IIAR 7 update now open for Public Review

November 10th, 2017 To: IIAR Members Re: First (1st) Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems. A first (1st) public review of draft standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems is now … Continue reading

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RAGAGEP Hierarchy in Application – A worked example

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading

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Why we changed our element “Guidelines” to be called “Written Plans”

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading

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What training does my refrigeration operator need?

Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation. Understanding the requirements of PSM/RMP training for Operators The Training element in PSM (1910.119(g)) and … Continue reading

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Management Of Change (MOC) for Personnel

In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading

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