Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Learning from Failure

Posted on May 17, 2018 by Brian Chapin

“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading →

Posted in Culture, General Information, Good Engineering Practices, Incidents, OSHA, System Optimization | Tagged , , , , , | Comments Off on Learning from Failure

What you need to know about Repeat Citations

Posted on March 9, 2018 by Brian Chapin

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading →

Posted in Compliance, General Duty, General Information, NEP, OSHA | Tagged , , , | Comments Off on What you need to know about Repeat Citations

General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

Posted on February 26, 2018 by Brian Chapin

Several times a year I get a phone call or an email from a client that wants to lower the NH3 inventory below the federal 10,000lb threshold so they are no longer subject to the PSM/RMP rules. It’s a conversation … Continue reading →

Posted in Community Involvement, Compliance, General Duty, Good Engineering Practices | Tagged , , , , | Comments Off on General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

IIAR 7 update now open for Public Review

Posted on November 10, 2017 by Brian Chapin

November 10th, 2017 To: IIAR Members Re: First (1st) Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems. A first (1st) public review of draft standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems is now … Continue reading →

Posted in Compliance, SOP Development, Standardization | Tagged , , , , | Comments Off on IIAR 7 update now open for Public Review

RAGAGEP Hierarchy in Application – A worked example

Posted on October 10, 2017 by Brian Chapin

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading →

Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA | Tagged , , , , , | Comments Off on RAGAGEP Hierarchy in Application – A worked example

PHA Worksheets Template updated

Posted on August 2, 2017 by Brian Chapin

The Template What-If / Checklist worksheet used to guide PHA Studies has been modified. The Identification and Review of Past Incidents section has been renumbered with some new questions concerning the performance of the Incident Investigation element added before the example / … Continue reading →

Posted in Compliance, EPA, Standardization | Tagged , | Comments Off on PHA Worksheets Template updated

Why we changed our element “Guidelines” to be called “Written Plans”

Posted on July 28, 2017 by Brian Chapin

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading →

Posted in General Information, Standardization, System Optimization | Tagged , , | Comments Off on Why we changed our element “Guidelines” to be called “Written Plans”

What training does my refrigeration operator need?

Posted on July 11, 2017 by Brian Chapin

Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation. Understanding the requirements of PSM/RMP training for Operators The Training element in PSM (1910.119(g)) and … Continue reading →

Posted in EPA, Operator Training, OSHA, Training | Tagged , , , , , , | Comments Off on What training does my refrigeration operator need?

Management Of Change (MOC) for Personnel

Posted on April 19, 2017 by Brian Chapin

In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading →

Posted in Compliance, Management of Change, System Optimization | Tagged , , | Comments Off on Management Of Change (MOC) for Personnel

Outsourcing your Contractor Selection Process – Can it be done?

Posted on April 11, 2017 by Brian Chapin

Over the past few years we’ve seen an increase in the number of companies that use a 3rd party service to qualify their contractors. Often, these services screen the prospective contractor for their safety record / programs, insurance history / … Continue reading →

Posted in Compliance, Contractors | Tagged , , | Comments Off on Outsourcing your Contractor Selection Process – Can it be done?