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Author Archives: Brian Chapin
Learning from Failure
“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 Incidents, Lessons Learned, OSHA, PSM, RAGAGEP, RMP
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What you need to know about Repeat Citations
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 Fines, NEP, OSHA, PSM
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General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?
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 DHS, EPA, Fines, General Duty, OSHA
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IIAR 7 update now open for Public Review
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 PSM, RAGAGEP, RMP, SOP, Standardization
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RAGAGEP Hierarchy in Application – A worked example
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 EPA, Mechanical Integrity, OSHA, PSM, RAGAGEP, RMP
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PHA Worksheets Template updated
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 PHA, Process Hazard Analysis
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Why we changed our element “Guidelines” to be called “Written Plans”
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 PSM, RMP, Standardization
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What training does my refrigeration operator need?
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 Employee Involvement, EPA, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
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Management Of Change (MOC) for Personnel
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 Management of Change, PSM, RMP
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Outsourcing your Contractor Selection Process – Can it be done?
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 Contractors, PSM, RMP
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