Tag Archives: RMP

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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Merry Christmas from the EPA!

Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … Continue reading

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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

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EPA RMP Executive Summary

As part of GCAP’s PSM course, we pull the publically available RMP from RTKnet.org for each facility in the class. We’ve seem some strange things in the Executive Summary and wanted to share some guidance on what exactly should and should not … Continue reading

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EPA goes after a cold storage, the real estate agent AND the customer leasing the space!

Complainant issued a Compliance Order to Respondent, and also to Quirch Foods Caribbean, Corp., and Caparra Realty Associates, LLC ( “the Order”) pursuant to Section 1 13 of the Act regarding the Facility. The Order required these parties to perform … Continue reading

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Paying for PSM, California Style

The state of California is having some trouble funding their oversight of their state PSM rule: CalARP. Don’t worry though, they have a solution… The Department of Industrial Relations, Division of Occupational Safety and Health (DOSH) is proposing to adopt emergency … Continue reading

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How do I deal with recommendations to my program?

You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading

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The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading

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So, you need a PSM coordinator…

The Situation: Several times a month I get a call from a recruiter or a facility that desperately needs to fill a PSM coordinator position. They quickly learn something that many people in our industry are unaware of – quality … Continue reading

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