Comments for TAO Compliance - PSM News for Ammonia Refrigeration

Comment on Speaking their language… by Brian Chapin

Brian Chapin — Fri, 09 Dec 2011 01:01:54 +0000

1910.119(g)(3)
Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Any type of documentation that contains the above things will work. Generally speaking you have three options for verification: written, verbal and observed.

Comment on Speaking their language… by Terry Shelton

Terry Shelton — Thu, 22 Sep 2011 01:24:30 +0000

Brian,
Are you required to document that they understood the training and if so how would you go about this documentation? Also where in the OSHA regulations would I find this requirement? Thanks for your assistance.

Comment on The Five Stages of PSM Grief by Tom Walker

Tom Walker — Tue, 16 Aug 2011 19:49:01 +0000

Thank you for this humorous take on what a pain it is to deal with management on PSM/OSHA compliance issues. I had one manager tell me, ” Tom, I saw the PSM program you had at S____. You guys went top notch all the way. We decided to do the minimum”. I’d like to know where he got his idea of “minimum”. Another manager actually had the gall to tell me at a safety committee meeting that “company policy superseded code”. Every time I feel my blood pressure going up I’ll take a time out and read your “Five Stages of PSM Grief”.

Comment on OSHA PSM National Emphasis Program Extended by Brian Chapin

Brian Chapin — Mon, 23 May 2011 19:30:52 +0000

The one I hear about consistently is the CGAP NEP course. I'm quite a believer in their programs.

Comment on OSHA PSM National Emphasis Program Extended by Anthony Frosos

Anthony Frosos — Mon, 23 May 2011 17:33:21 +0000

Brian is there any good training out there for NEP? i’m looking on expanding my knowledge base and be better prepared for any compliance audits from Osha.

Comment on Do I need to train this contractor? by Brian Chapin

Brian Chapin — Wed, 20 Apr 2011 09:07:15 +0000

The 1.5″ pipe in question was installed in the early 60′s, Miguel.

Comment on Do I need to train this contractor? by miguel sanchez

miguel sanchez — Wed, 20 Apr 2011 00:24:41 +0000

It’s scary situation but can definitely happen at any given time. For those who are familiar with the ammonia process, we need to always lend a safe eye to any personnel working on or around an ammonia system. Every one deserves to go home every day regardless of there inexperience. By the way 1.5″ HPL pipe should be schedule 80!

Comment on Ice Buildup: The worst case scenario by Peter Thomas

Peter Thomas — Thu, 07 Apr 2011 18:09:11 +0000

Brian – Thanks for sharing. It has always amazed me how heavy a completely iced coil can become. In a project that we constructed last year the operating weight of the coils was 2,000 lb, but the iced weight was 4,700 lb! It is very important that everyone understand that a building must be designed for the iced weight and not just the operating weight. Thanks again for sharing.

Comment on Update your RMP Every 5 Years by Brian Chapin

Brian Chapin — Fri, 21 Jan 2011 21:55:11 +0000

You’re exactly right Peter. #8 is also the one I find most often – in fact I have actually had the EPA try to reach an emergency contact and get a disconnected number. They then tried the secondary contact that was the Security Company at the facility. The security company refused to give the EPA inspector a contact at the company. Needless to say he wasn’t very pleased by the time I talked to him!

Comment on Update your RMP Every 5 Years by Peter Thomas

Peter Thomas — Fri, 21 Jan 2011 17:56:13 +0000

Thanks for sharing Brian and putting together this blog. Its also important to note that there are other things that can trigger the need to submit a corrected/revised RMP to the USEPA. A revised RMP must be submitted within the following time period for the following reasons

1. Within 6 months of a change that alters the Program level of a process
2. Within 6 months of a change that requires a revised offsite consequence analysis
3. Within 6 months of a change that requires a revised PHA
4. No later than the date on which a regulated substance is first present above a threshold quantity in a new process
5. No later than the date on which a new regulated substance is first present in an already covered process above a threshold quantity
6. No later than 3 years after a newly regulated substance is first listed by the USEPA
7. Within 6 months of new accident history data becoming available
8. Within 1 month of a change in emergency contact information

I’ve found that #8 is especially important to keep in mind because people change jobs often and it is not always the first thing on the mind of the new emergency contact to update the RMP.