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Author Archives: Brian Chapin
Site Update
Almost all my new posts are on RCE Chill. I only post things here that are controversial personal opinions. If you are looking for information on the OSPSM project, an Open-Source resource for PSM and Safety Templates please contact me. … Continue reading
Posted in General Information
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Yeah, but No – Compliance vs. Safety
Often, compliance and safety go hand-in-hand. This leads us to believe they are the same thing. Occasionally they are not; and when that’s the case, it is our duty to place SAFETY above Compliance. Relief Piping Termination – A worked … Continue reading
Posted in General Information, Good Engineering Practices
Tagged PSM, RAGAGEP, RMP
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IIAR 2-2014, Addendum A Third Public Review
The IIAR has announced a 3rd Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems. This brings some interesting changes to IIAR 2 . Two of these proposed changes are : Clearing up the … Continue reading
Posted in Compliance, Good Engineering Practices, IIAR
Tagged RAGAGEP
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EPA RMP update “Delay” rule vacated by DC District Court
EPA retains authority under Section 7412(r)(7) to substantively amend the programmatic requirements of the Chemical Disaster Rule, and pursuant to that authority, revise its effective and compliance dates, subject to arbitrary and capricious review. . . . the agency must … Continue reading
Posted in Community Involvement, EPA
Tagged EPA, RMP
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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
Posted in Compliance
Tagged PSM, RMP, Standardization
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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
Posted in Community Involvement, General Duty, Incidents
Tagged EPA, General, Incidents, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
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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
Posted in Compliance, EPA, IIAR, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RAGAGEP, RMP
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IIAR 6 Public Review #3
Make your opinion known BEFORE the changes go final! IIAR 6 continues its development. This document will replace IIAR Bulletin 110 (among others) and will be very important. The current review only lists changes since Public Review #2. To: IIAR Members … Continue reading
Worksite Posters
Head on over to RCE-Chill to see our latest worksite posters.
Posted in Oddities
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Yet another update on the RMP Updates!
Today, EPA’s Administrator, E. Scott Pruitt, signed a new proposed rule, further changing the Obama-era EPA’s proposed changes and the EPA is submitting that for publication in the Federal Register (FR). Basically, it outlines two proposals for the Obama-era EPA’s … Continue reading