Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

2017 SOP Template Updates

The SOP reference element guideline and RESOP/ROSOP reference  templates have been updated for 2017. The changes are basically broken into two groups: Continuous Improvement and IIAR 7. Continuous Improvement: As always, there are a lot of little change suggestions that … Continue reading

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Merry Christmas from the EPA!

Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … Continue reading

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Pencil-Whipping can Kill

What is it? Pencil-whipping is when you complete a form, record, or document without having performed the implied work or without supporting data or evidence. Here are some common examples in NH3 refrigeration: Completing “word orders” without conducting the work … Continue reading

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Militarized Incompetence or Unintentional Sabotage

  In 1944, near the end of WW2, the Office of Strategic Services (the forerunner to the CIA) released a field guide called the “Simple Sabotage Field Manual.” The purpose of the suggestions in the manual was “to present suggestions … Continue reading

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APR’s aren’t Magic

When I see people writing “Have a Full-Face APR (Air Purifying Respirator) nearby, within arm’s reach” in their Line/Equipment Opening (aka Line Break) procedures, my blood-pressure shoots through the roof. Yes, I know I am a rather excitable guy by … Continue reading

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We’re all in this together

It was great to meet so many friends and colleagues in Las Vegas last week for RETA’s annual conference. While all business is about personal relationships, most people recognize that the Ammonia Refrigeration industry is a uniquely tight-knit group. I’ve … Continue reading

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When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?

First off: What is a Car-Seal program and what does it do?  A Car-Seal program is designed, implemented and managed to ensure that safety-critical valves within the covered process are maintained in their safety-critical position / setting during normal system … Continue reading

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DHS CFATS Top-Screen Update

It looks like the DHS has finally got around to updating their Top-Screen program. Below is the email from them: ——————————————————————————– Subject: Enhanced CFATS Risk-Assessment Methodology and Upcoming Requirement to Submit CFATS Top-Screen From: “cfatsupdate” <[email protected]> Date: Tue, August 30, … Continue reading

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Appeals Court upholds Contractor PSM Citations

A maintenance contractor that provides skilled labor to perform skilled labor, electrical and mechanical work was cited by OSHA for violations of the PSM standard after their employee was injured by a chemical release. OSHA threw the book at them … Continue reading

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OSHA increases fine amounts by 78%!

In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. The Department of Labor is adjusting penalties for its agencies, including the Occupational Safety and Health Administration (OSHA). OSHA’s maximum penalties, which … Continue reading

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