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Author Archives: Brian Chapin
The coming (and current) operator shortage…
One of the biggest issues facing an Ammonia refrigeration facility today is finding qualified and competent technicians to operate and maintain the system. It’s not uncommon for me to receive 2-3 emails or calls a week asking for help finding … Continue reading
Posted in General Information, Good Engineering Practices, Operator Training
Tagged Efficiency, Operator Training, PSM
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Two recent NH3 Refrigeration Fines
US Labor Department’s OSHA cites Rochester, NY, milk products manufacturer, proposes more than $200,000 in fines, for repeat and serious hazards. . $153k of the citations are Repeat citations. . Failing to address the hazards of oil draining in the PHA. … Continue reading
Posted in Compliance, General Information, Good Engineering Practices, NEP
Tagged Fines, OSHA, PSM, RAGAGEP, SOP
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Shocking EPA video
Given some of the stories I’ve heard recently from the Ammonia Refrigeration industry, I can’t help but wonder if the strategy exposed in this video is also being used on us. Top EPA official, Region VI Administrator Al Armendariz, using … Continue reading
Posted in General Information
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Relationships matter!
Bear with me for a few minutes, because this is going to start out talking about one thing but end up talking about something entirely different. . Beef Products International (BPI) has been in the news lately because their product … Continue reading
Posted in Community Involvement, General Information
Tagged Incidents
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What to do when litigating an OSHA citation
Timothy W. Hoover, writing in the “The Daily Record” has an excellent article explaining the steps to contest an OSHA citation. Consider reading it all!
Refresher Training
Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading
Posted in Compliance, Operator Training, System Optimization
Tagged Employee Involvement, EPA, Operator Training, OSHA, PSM, RMP, SOP, Standardization
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A debate on Management of Change
Recently a group of safety yahoos got together to discuss a situation: You have a freezer with racking. The racking needs to be removed for XXXX reason. You hire a contractor to do the job. You evaluate and train the … Continue reading
Posted in Contractors, General Information, Incidents, Management of Change, NEP, Standardization, System Optimization
Tagged Contractors, Incidents, OSHA, PSM, RMP, Standardization
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No NH3 Detection – General Duty Citation in store?
Most General Duty citations have nothing to do with Ammonia refrigeration but I’ve started to see a trend recently where processes that are not covered by PSM are being subject to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). The … Continue reading
Posted in Compliance, General Information
Tagged Fines, General Duty, OSHA, RAGAGEP
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Website Availability of Non-OCA RMP Data
Email from the EPA: . As you know, EPA regulates certain hazardous chemical facilities under 40 CFR Part 68 – known as the EPA Chemical Accident Prevention or Risk Management Plan (RMP) program. EPA is aware that state and local … Continue reading
Posted in Community Involvement, General Information
Tagged EPA, RMP
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PSM Covered Chemical Facilities National Emphasis Program goes NATIONWIDE!
OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (See Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119). These incidents spurred broad recognition that releases of highly hazardous chemicals … Continue reading
Posted in Compliance, NEP
Tagged Fines, OSHA, PSM
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