Hansen Relief Valve Recall

If you use Hansen relief valves, this bulletin might be of use to you:
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Hansen recently discovered that certain pressure relief valves sold to our customers for industrial use from February 16, 2011 to April 4, 2013 are more susceptible to internal corrosion when exposed to standing water inside the valve. Even though the risk is remote, the failure of a pressure release valve could conceivably result in serious personal injury and/or property damage. Consequently, Hansen has initiated a program to send replacement valves so that any valves currently at risk can be replaced promptly. Hansen has not received any reports to date of any valve failures that have resulted in personal injury or property damage, but Hansen is taking this action in the interest of safety and avoiding potential risks. We are therefore issuing this recall of all valves that may be potentially impacted.

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Specifically, Hansen H5600A, H5601, H5602, H5600R, H5602R, and H5632R valves with serial numbers 02B11 through 04B13 are susceptible, regardless of pressure setting.

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You can download the notification bulletin here.

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West Texas Damage Photos

I took a lot of pictures today while touring the damage in West, Texas. The album is open for viewing but I warn you that I am not a photographer and sometimes take a half dozen pictures of the same thing hoping one will turn out ok.

You can view the album at this link on Google+

The damage was truly horrific and I am very surprised that more people didn’t lose their life to this tragedy.

Remember that you can donate to the survivors at RETA.

Posted in Community Involvement, Incidents | Tagged | 2 Comments

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 PSM practitioners are rare, usually already employed and very expensive!

Now, it’s certainly possible to entice someone out of their current job, but it’s going to be a very expensive proposition. If you need somebody right away there aren’t many other options, but if you have time to plan for the PSM coordinator/manager position, there is often a much better solution: Build your own!

That’s right – take someone you already have in your organization, someone who already possesses the hard to replicate skills, and then train them into the job. Interested? Let me show you how it can be done! First, we have to identify the skills…

The Skills: I’ve visited a hundred or more PSM covered processes and audited just about every kind of PSM program for Ammonia Refrigeration. After a while, you start asking yourself: “Is there a common thread?” to what works and what doesn’t. There seems to be a certain type of person that does very well in the PSM role. These aren’t people who end up hating their PSM duties – they are people who come to love them! These people have a few common skills. While these skills aren’t the ones that many people think of when dealing with PSM, in my experience, they are the ones that often decide between failure and success.

  1. Curiosity – Why do we work this way? How does that work? Who should be doing this? That’s right, plain old curiosity is a rare thing these days. I’ve been to bottling plants and asked the line operator who worked there for a decade how many bottles his machine processes an hour, only to find out that it never occurred to him to ask. This is not the kind of person you want in your PSM role! You need someone who is intensely curious. You need the kind of person who will spend a half day doing internet searches on “Maximum Intended Inventory” before feeling comfortable that the issue is covered in your program. It’s the kind of person that says: “Well, it’s asking for Maximum Intended Inventory and this document has those words in the title, so we must be good” that get you into trouble.
  2. Detail Oriented – I’m not talking about typical levels of detail. I’m talking about an almost pathological need for order and accuracy. Oddly, every single PSM coordinator I know that is good at what they do obsesses about document formatting. That sounds odd, doesn’t it? I think it actually points to something more important: the kind of person that notices the fonts don’t match, that the margins are off, or that the bullet points don’t line up, is also the kind of person that is going to notice much more important things, like incorrect valve numbers. Detail oriented people are also good at taking notes – the kind of notes that actually document what happened in a meeting rather than notes that look like a bad powerpoint rendition of the meeting.
  3. Technically Proficient – I’m not talking about technical proficiency in Ammonia refrigeration. I mean that this is the kind of person who is willing to pick up a manual and set the time on their microwave after a power outage. If you’re the kind of person who has a houseful of electric clocks blinking 12:00, that doesn’t make you a bad person; it’s just not likely you will be a good PSM coordinator. Most important though is the ability to translate the written word into action. You see, as a PSM coordinator that’s exactly what you need to happen – the policies, guidelines and procedures need to become reality through the actions of the people operating the system. If you can’t take the written word and apply it, then you aren’t going to be able to take the action and document it in the written word either.
  4. Computer Skills – I’ve trained operators to write SOPs all over the country and the biggest hurdle is always getting them to use a computer to write. It’s as painful to watch most operators type as it is for them to watch me work on a car engine – and nearly as futile. You see, the skills that you need to create, modify and manipulate documents in Word, Excel, etc. are not in any way useful to the average blue-collar mechanic. For that reason, they don’t bother to develop them – and frankly it would be a waste of time for most of them to do so. They already have valuable skills and their time is better spent honing the skills they already possess or building new ones that complement those skills. Just as there are people who specialize in maintenance, there are also people that specialize in working with computers to produce and manage documents.
  5. Personal Skills – They don’t need to have been voted prom queen/king, but they need to be able to work with people across all levels of the organization. They also need to be able to work with outside vendors, consultants, government officials, regulators, etc. in a professional capacity.

Ok, from what I’ve seen, that’s the list. That’s the skillset that pretty much defines success in the Ammonia Refrigeration PSM role. I am pretty sure you don’t have anyone like that in the maintenance department. In fact, most food or cold storage plants don’t have many people like that in their buildings, let alone their maintenance department. Where are you going to find someone like that?

One Possible Solution: You’ll have to go to a place where those skills are rewarded, where people are hired and retained based on those skills. Do you know where that is in your facility? Believe it or not, most companies have someone they can train into a good PSM coordinator sitting around answering phones and scheduling appointments. That’s right: somewhere you have a standout secretary/personal assistant who has the raw material to be a good PSM coordinator.

Perhaps you are saying to yourself: But secretaries don’t know anything about Ammonia Refrigeration! Well, you’re right; but the reality is that it’s fairly easy to teach a curious, detail oriented, technically proficient person with computer skills what they need to know about Ammonia Refrigeration. It’s certainly a lot easier than it is to teach most Ammonia Refrigeration Mechanics all of those other skill sets that a secretary already has. Remember, we’re not trying to turn this secretary into a great refrigeration mechanic. We just need this new PSM coordinator to know enough about the process that they aren’t stepping on mechanic’s toes or devising silly policies.

A Challenging Transition: How would we make that transition? Well, to make the rest of this conversation easier, let’s imagine a fictional character named Natalie who is already a fairly competent secretary / personal assistant. She’s been with the company for over five years and has a track record of success – she’s a known quantity, something that can’t be said for some outside hire with a fancy resume. She’s got all the requisite skills we’ve outlined above and it turns out she’s sort of bored to tears in her job. It’s obvious if you think about it – she’s already involved in every volunteer committee the work place has to offer. She is always trying to help people out and her role in the office exceeds the actual scope of the job because she’s just the “go-to” person when you need something done.

The Maintenance Manager approaches Natalie with this unique career change. She’ll get to move out of the office and closer to the action – where the products are being made. As we said, Natalie is interested in a challenge, but she wasn’t so unsatisfied that she was looking for another employer. She readily accepts because this opportunity allows her to grow professionally while keeping all her seniority, benefits, vacation time, etc.

A Realistic Training Plan: We’re not going to throw Natalie to the wolves here – we have to train her to do the job she’s been assigned to do. We’re going to start with a little “overview of the process” training. That’s essentially going to involve following around our lead refrigeration technician for two weeks while he/she does the job of a refrigeration mechanic. We’re just trying to get her a little familiarity at this point so we’ll encourage her to ask questions but we’re not expecting any actual hands-on work out of her at this point.

After this two week familiarity training, we’ll pack Natalie off to a 4-day Operator 1 class at a quality ammonia school like GCAP. At the school she’ll learn the basics of refrigeration – how and why it works. Once she’s back from her training, we’ll put her back on shadow duty with that lead refrigeration technician but this time we’ll encourage her to get her hands a little dirty: Maybe help drain some oil pots, swap out filters or coalescers, clean out condensers, etc. We’re not really expecting Natalie to become a mechanic here – we’re just trying to make sure she gets a feel for the tempo and nature of the job.

When the technician is doing things that Natalie has already done, she’ll be expected to spend that down-time familiarizing herself with the existing PSM documentation. When we feel she’s ready (likely just few weeks) we’ll send her off again for some PSM training. (I am admittedly biased because I teach PSM at GCAP, but in all honesty there is no PSM course for Ammonia Refrigeration that holds a candle to the course GCAP provides). By waiting a few weeks to allow Natalie to familiarize herself with the job and the equipment, we’ve really set her up for success at this class!

When Natalie comes back from her training, we’ll ease her into the role of PSM coordinator, starting off by having her perform a Gap Analysis on the PSM system. In this Gap Analysis she’ll compare the requirements of the PSM standard she’s learned and the examples GCAP provided with her documentation at the facility. She’ll list the deficiencies, prioritize them and bring them to the management team. Natalie has just set herself up with a good 3 months’ worth of training/work!

Conclusion: You see how this would all work? I know it works in the real world, because I’ve seen it work across the country. The problem our industry faces is that the kinds of people who make great PSM coordinators are generally not the kind of people who gravitate to maintenance departments. Most of the people who have the right skills aren’t even aware that Ammonia Refrigeration and PSM even exist! You’re going to have to go out there and find them, bring them in, and start them off on a uniquely rewarding career. 

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Texas Ammonia Explosion Coverage

Just a quick note – I hope to update this later.

The explosion in Texas has caused some reporters to imply that the company’s RMP filing for Anhydrous Ammonia was inaccurate because the “Worst Case Scenario” didn’t include an explosion of the Ammonia Nitrate at the facility.

The “Worst Case Scenario” isn’t something the facility gets to decide – it’s set in the LAW by the EPA at §68.25(c)(1)

“(c) Worst-case release scenario—toxic gases. (1) For regulated toxic substances that are normally gases at ambient temperature and handled as a gas or as a liquid under pressure, the owner or operator shall assume that the quantity in the vessel or pipe, as determined under paragraph (b) of this section, is released as a gas over 10 minutes. The release rate shall be assumed to be the total quantity divided by 10 unless passive mitigation systems are in place.”

It would seem that the facility was taking advantage of the “retail exemption” in the PSM rule to avoid being a PSM covered process as they filed their RMP as a L2 process. Note that Ammonia Nitrate is not a covered chemical under the PSM or RMP rule.

Update: John Astad has a good roundup of how widespread this issue can be.

Posted in Community Involvement, Compliance, EPA | Tagged , | 1 Comment

EPA & Tyson agree to settle in a BIG way

The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice announced a Clean Air Act (CAA) settlement with Tyson Foods, Inc. and several of its affiliate corporations to address threats of accidental chemical releases after anhydrous ammonia was released during incidents at facilities in Kansas, Missouri, Iowa, and Nebraska, resulting in multiple injuries, property damage, and one fatality.

Tyson is required to, as part of the settlement embodied in the Decree:
  • Conduct third-party audits of its current compliance with the Clean Air Act’s Risk Management Program requirements at its 23 facilities in EPA Region VII that operate on or more covered processes (ammonia refrigeration equipment). The Audit Protocol requires that third-party auditors with expertise in ammonia refrigeration systems and who are recognized experts in PSM/RMP compliance conduct paper reviews of Tyson’s engineering and design specifications as they relate to the physical systems of the covered processes at the facilities. The Auditor shall next conduct on-site Audits of the ammonia refrigeration systems at all the facilities according to a schedule set forth in the audit protocol. Within 30 days after the completion of each on-site Audit, the Auditor shall provide a report to Tyson and EPA. Within 45 days of receiving the Audit report, Tyson shall submit a response to EPA which shall include a plan to correct identified violations within 6 months for non-capital expenditures and within 12 months for capital expenditures. Once Tyson has completed implementation of any corrective measure, Tyson shall certify the completion of the work.
  • In addition, Tyson has agreed to perform non-destructive testing at certain piping used in its refrigeration systems at the 23 facilities. The non-destructive testing is designed to identify piping that was partly responsible for some of the anhydrous ammonia releases by testing threaded piping connections less than two (2) inches in diameter because of their potential for failure.

The settlement includes a 3.95 million dollar fine and requirements to conduct external (3rd party) audits on 23 facilities. Furthermore, as stated above, those audits must be shared with the EPA who also is requiring a written plan to address the issues including a time limit to do so. I am somewhat familiar with Tyson’s PSM/RMP efforts and consider them above-average for our industry – something that should give all of us some reason to reconsider our PSM/RMP priorities.

You can see the settlement information at this link: http://www.epa.gov/enforcement/waste/cases/tysonfoodsinc.html

The Consent Decree in total:

http://www.epa.gov/enforcement/waste/documents/decrees/tysonfoodsinc-cd.pdf

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Are Oil Separators a Confined Space?

Quite a few people have been reporting that OSHA inspectors and consultants are making an issue of people not classifying their compressor oil separators as a confined space. This is vexing because unless your oil separators are “large enough and so configured that an employee can bodily enter and perform assigned work” it wouldn’t appear that the standard (1910.146) applies to them. While I agree that the standard itself might cause confusion, the “Summary and Explanation of the Final Rule” is fairly clear on the matter:
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Proposed paragraph (b)(23)(i) stated, as the first criterion, that a space had to be “large enough and so configured that an employee can bodily enter and perform assigned work” in order to be considered a permit-required confined space. Several commenters (Ex. 14-4, 14-42, 14-94, 14-99, 14-143) stated that it was confusing for proposed paragraph (b)(23)(i) to provide that a permit space was sized and configured for bodily entry when the definition of “entry” provided that entry began when the employee’s face broke the plane of the opening into the space. Some of the commenters (Ex. 14-42, 14-94) noted that the proposed definition excluded spaces which contained hazardous atmospheres and into which employees were able to insert only their heads and shoulders. For example, Mr. Martin Finkel, a Certified Marine Chemist with Marine & Environmental Testing, Inc. (Ex. 14-4) stated:

The definition of Permit Required Confined Space, as stated, does not allow for small space[s] which permit entry of a worker[‘]s head, but not his/her whole body. Such a space may prove just as hazardous if it contains an IDLH atmosphere which the worker breathes. I recall seeing photos of a [fatality] on a barge where only the worker’s head was in the tank – his body remained sprawled on deck – yet the worker was just as dead as if he had entered bodily. Therefore, I suggest removing [paragraph (b)](23)(i) entirely from the definition of Permit Required Confined Space.

The Agency has not adopted this suggestion. While OSHA is concerned that spaces that are too small for complete bodily entry may pose hazards for employees, the Agency did not intend to cover such spaces under the permit space standard. OSHA believes that the NPRM preamble discussion of permit space incidents and of proposed provisions clearly indicates that the proposed rule was intended to cover only spaces that were large enough for the entire body of an employee to enter. As commenters have correctly noted, the proposed definition of “permit required confined space” did not cover the “small” spaces. Such spaces do not meet the definition of “confined space”, nor do they pose hazards comparable to those associated with confined spaces. Since an employee cannot totally enter such spaces, he or she should not have difficulty withdrawing from the space. In order for a space to be considered a permit-required confined space, it must first be a confined space. A space that cannot be entered is not confined; therefore, it does not pose hazards related to the difficulty of exiting the space.

OSHA realizes that an employee may still be injured or killed as a result of some atmospheric hazard within such an enclosed area; however, this standard is not intended to address all locations that pose atmospheric hazards. The Agency believes that the procedures necessary to protect workers from atmospheric hazards alone are not those required by this standard, but are required by other OSHA standards, such as Subpart Z of the General Industry Standards. The exposed employee must also have difficulty exiting the space for many the requirements of section 1910.147 to apply. For example, the need for an attendant to be present is doubtful. Spaces that cannot be entered are small enough to be readily ventilated(8), and in many cases a reaccumulation of a hazardous atmosphere is highly unlikely. Because the requirements set forth in final section 1910.146 are not appropriate for application to spaces into which an employee cannot completely enter, OSHA has retained the language proposed in paragraph (b)(23)(i), which appears under the definition of “confined space” in the final rule.

While oil separators may present safety issues that require addressing in your Process Hazard Analysis, it seems fairly clear that almost all of them are not covered by the Permit Required Confined Space standard.

2018 Update: 5 and a half years ago when I wrote this, I used very specific language in the beginning of the article:

…unless your oil separators are “large enough and so configured that an employee can bodily enter and perform assigned work” it wouldn’t appear that the standard (1910.146) applies to them…

Recently, I’ve come across some very large compressors where the separators ARE “large enough” than an employee could bodily enter them. In those cases, the Confined Space rule would apply.

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The real cost of an OSHA/EPA fine isn’t the check you write

Sure, it’s painful to write a check to pay fines, but if you think that fine is the cost of OSHA/EPA non-compliance, you’re in for a rude awakening. The real cost of a fine from OSHA or the EPA isn’t just the number on the check, it’s a combination of Money, Time and Reputation.

Money – Sure, that check you write is money off the bottom line, but it also represents lost opportunities. Every dollar you pay in fines is a dollar you can’t spend to improve efficiency. It’s a dollar you can’t spend to expand your business. It’s a dollar you can’t spend on improved employee benefits. It’s a dollar you can’t spend on improved safety. It’s a dollar you can’t spend in the best interests of your business.

Time – You will spend an awful lot of time dealing with the aftermath of a fine. There are abatement documents, compliance meetings with officials, required follow-up, etc. Every second of that time is wasted time: time that would have been better spent doing the things your business is in business to do.

Reputation – You likely spend a small fortune building the brand name of your company and your products. Here is what the press release will look like:

The U.S. Department of Labor’s Occupational Safety and Health Administration has cited YOUR COMPANY for 15 alleged willful and serious violations of safety and health standards at its YOUR LOCATION, processing facility. The company faces a total of $279,000 in proposed fines, chiefly for deficiencies in its process safety management program.

“The requirements of OSHA’s PSM standard are stringent and comprehensive because an ammonia leak could have a severe or catastrophic effect on the plant’s workers,” said OSHA’s area director for YOUR LOCATION. “In this case, YOUR COMPANY knew that aspects of its PSM program were incomplete or inadequate and did not take steps to address those deficiencies. It is imperative that this employer scrutinize, update and properly maintain each element of the process to minimize hazards and protect its workers’ safety and health.”

Here’s what the headline for this story on the front page of your local newspaper will look like: YOUR COMPANY endangers workers.

Even if you manage to successfully appeal the fine, do you think the article that mentions your fines were dropped will be given the same prominence as the one that slandered you?

There’s also the increased scrutiny you will receive, both internally and externally. Internally your employees will start second-guessing every safety decision you make. Externally the regulatory agencies are more likely to visit you – it’s amazing how random audits seem to hit the same companies year after year!

The final cost to your company from an OSHA/EPA fine will dwarf the amount listed in the fine. Obviously we want to take our PSM/RMP obligations seriously to ensure the safety of our employees and the environment, but we should also be mindful of our PSM/RMP program’s role in COST AVOIDANCE as well.

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Maximum Intended Inventory (1910.119(d)(2)(i)(C))

Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you to declare a “Maximum Intended Inventory.” What does that actually mean? Well, it’s often confused with the inventory calculation – or what’s more commonly called the charge calculation.

First, let’s first look at the guidance from OSHA and the EPA:

OSHA: Process technology information will be a part of the process safety information package and it is expected that it will include… employer established criteria for maximum inventory levels for process chemicals; limits beyond which would be considered upset condition…

EPA: You must document the maximum intended inventory of any vessel in which you store or process a regulated substance above its threshold quantity. You may want to check with any trade association or standards group that develops standards for your industry to determine if there are any limitations on inventories. For example, in some cases the maximum capacity of a tank may be 10,000 gallons, but an industry standard may recommend that the tank never be filled to more than 85 percent capacity. If you follow the standard, your maximum inventory would be 8,500 gallons.

We’re going to want to declare three things by the time we are done with this inventory issue:

1)     The ACTUAL charge of the system – The ACTUAL amount of Ammonia in the system. You can calculate this directly with NH3 properties charts and the PSI information on your piping and vessel volume. This is the number that decides if you are required to have a PSM/RMP program.

2)     The MAXIMUM inventory of each process vessel. Ammonia moves around the system and therefore vessels will often have more or less than the amount listed in the actual inventory calculation. We have to set a limit that we will allow in each vessel. MANY people decide to set this as 80% based on old RETA books. I would think that’s a maximum fill level to avoid hydraulic trapping but you shouldn’t rely on a rule of thumb – you will need to have an engineering reason for this number. This number is decided upon based on your PSI information and the Process Hazard Analysis you do.

3)     The MAXIMUM intended inventory of the system – the MAXIMUM amount of Ammonia you would ever want to put in the system under any circumstances. You will want to include some sort of procedure or policy that ensures this level is not exceeded – make sure this procedure or policy is audited as well. You could figure out this number by adding up all the figures you calculated in step #2.

It’s a good idea to document all the above in a letter to file explaining the quality control SOPs and administrative controls you have in place in regards to inventory level. Make sure you also describe the auditing component to these inventory controls so you can ensure your administrative solution is working. It wouldn’t hurt to write this letter to file in plain language so it’s easily understood. I love these “Letters to File” is that when an inspector asks me a question about something, such as my inventory in this case, I can just hand her a document.

The difficult part – the part you will want to do with your PHA team is the second item: the maximum levels for each vessel. Some choose to set this level at their limit of their normal operating range. The problem with setting maximum intended inventory levels at your normal operating levels is that when you exceed them (and you will from time to time) you’ve invalidated the document and any reasoning you made from it.

So let’s take a simple recirculator package that normally runs at 30% full. You might set your normal operating levels between 20-40% and your maximum intended inventory at 80%. Of course, if you have issues with inadequate liquid separation above 70% or so you might set that maximum intended level lower. The number you choose here can’t be arbitrary – you need to have some sort of engineering reason to explain this choice. Furthermore you must DOCUMENT that reasoning to answer the most often failed OSHA question:

Why have the implementation decisions and priorities been made as recorded in the PSM documentation?

If you really want to understand this question and why it’s even asked, check out the CSB video on the texas city disaster which resulted from not understanding what the maximum intended level actually was.

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How should I FIX a PSM program?

This might be one of the most common questions we’re asked: How do I resurrect a PSM program that has been neglected?

Our answer is that you should deal with these broken programs no differently than if you are starting a completely new program. Before you can do that though, you should understand how PSM programs for Ammonia Refrigeration are created and implemented. We should strive to explain things as simply as possible so we’ve created some diagrams to help. First up, let’s make sure we understand how the elements work together, because although they are all intertwined, some rely on others being accurate:

Starting at the bottom and working your way up, this chart should give you an idea what elements need to be in place before you can work on the more advanced ones. If you focus on the second tier before the first tier is complete you’ll be re-writing all those guidelines and procedures for certain.

How do we create a working system? The following chart might help give you an idea because PSM implementation is not an EVENT, it is a PROCESS.

Essentially this chart boils down to this:

  1. Design your management system – who is responsible?
  2. Design your guidelines – how will you do this?
  3. Design you support material – what will they need to implement the guideline?
  4. Live the plan – how does this work in the real world?
  5. Fix the plan – Where you find that parts of the plan don’t work, fix them and return to step 4.
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What should you do if you get a notice of an EPA Risk Management Program inspection?

Depending on your area you may get anywhere from five days up to six weeks notice for a scheduled  inspection from the EPA. You aren’t going to create a compliant, living PSM/RMP program in that time frame but there are many things you can do to prepare the program you already have. Assuming you have a level 3 program in conjunction with a PSM program, here are three things you absolutely should do if you get notice of an inspection:

1) Know your material.

  • The RMP Level 3 checklist that most EPA inspectors use is freely available online. Go through it and make sure you have these items covered in writing and that you know where to find them quickly.
  • Check your documentation for accuracy: Every document you use to answer the questions in the RMP Level 3 checklist should be checked for accuracy. Are you doing the things the documents require in the way you say they will be done?
  • Check for open recommendations. Whether they’ve been generated through Employee Participation, Incident Investigations, Process Hazard Analysis, Compliance Audits or any other source, make 100% sure that you have addressed every one of these recommendations. You don’t need to have every one of them closed, but you need a plan of action and a schedule for those actions in writing.

2) Prepare the staff – including yourself.

  • Make sure everyone is aware that an inspection is going to happen.
  • You don’t want to be tripping over contractors so you may wish to schedule their work at times that don’t coincide with your inspection.
  • Remind your staff to “GO TO THE DOCUMENTS” in response to any PSM/RMP question.

Q: “How do you drain this oil pot?”

A: “With this written procedure.”

Q: “How much ammonia is in the system?”

A: “This inventory calculation sheet has the information you are asking for.”

  • Handle this as a professional learning opportunity and you’ll do much better. Rather than having a surly demeanor and saying “What do you want?” to an inspector, why not something more like “We put a lot of effort into our PSM/RMP program to protect our employees and the environment. We’re really looking forward to this opportunity to show you all the hard work we’ve been doing and perhaps find some ways we can further improve it in light of your experience.” Now you’ve complimented the inspector and expressed your company’s desire to meet the goals of the program – nobody loses there.
  • Relax: Remember they are auditing a program – not the people who implement it. It’s important that you take the inspection seriously but it’s not the inquisition. Don’t relax too much: I know of several inspections that went downhill rapidly because the staff were treating the inspection as a joke.
  • Put yourself in their shoes for a second. Inspectors are generally good people trying to do a good thing – treat them as professionals. There are appropriate venues to vent your feelings on the federal or state government – the inspection is not one of them. Inspectors are used to being treated awfully so why not be the exception and treat them as a welcome guest?
  • On the flip side – STAND YOUR GROUND. Support your program and your compliance efforts with RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) so the inspector is left to argue with the CCPS or the IIAR rather than you personally. Often inspectors will want to see something a certain way. When you are having an issue meeting their demands, ask them exactly what portion of the law they are referring to. PSM/RMP is a performance oriented standard – they picked the destination but your company gets to pick the path you take to that destination.

3) Prepare the facility

  • Part of the inspection will include a site tour. This is no different than a visit from your mother in law – you will want to put your best foot forward.
    • Plan out your route so the inspector gets to see everything they need to see while showing the facility in the best light.
    • Do some dusting, painting, re-labeling and tagging as needed. A little bit of housekeeping goes a long way in establishing good will.
  • LOOK at your system. A dented drain pan will draw questions about “struck-by hazards”, a fresh weld and unpainted pipe will draw questions about Management of Change, frost on insulation will draw questions about Corrosion Under Insulation and Non-Destructive Testing, etc. Be prepared for these questions and have ready answers.

The steps above WILL prepare you for an EPA inspection and they WILL improve your results. What they can’t do is cover up a program that has been neglected for years, but if you are reading this then that’s probably not your situation. Almost any program that has not been completely neglected can be improved and polished enough to pass most EPA inspections with the help of a great compliance consultant.

If you find yourself in need of some advice, some pre-audit assistance or a compliance audit / gap analysis, you can always call on your favorite resource for some assistance before the inspection. I would love to hear from you and help you prepare. You don’t have to be in this alone!

Posted in Compliance, EPA, Inspections | Tagged | Comments Off on What should you do if you get a notice of an EPA Risk Management Program inspection?