Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Lessons Shared #1 – “The Graveyards are full of Heroes”

Posted on March 6, 2014 by Brian Chapin

I had to fight back tears the first time I read this NIOSH report. Having lived on a family farm for a short period, it was very easy for me to imagine the reaction of the people involved… A 43-year-old … Continue reading →

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The “PSM Lessons Shared” project

Posted on February 27, 2014 by Brian Chapin

Recently, during a PSM class, I had a student with an all-too-common issue: How do I change the incident reporting culture at my facility? As a new PSM coordinator he was struggling because he couldn’t get his operators to report … Continue reading →

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Should you challenge OSHA citations?

Posted on February 3, 2014 by Brian Chapin

Will Kramer has written an excellent article on why you should challenge OSHA citations. Based on an analysis of the more than 57,000 citations listed in OSHA’s public inspection databases in 2012, employers achieved an average penalty reduction of 49% … Continue reading →

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H.R.1648 – Protecting America’s Workers Act

Posted on November 29, 2013 by Brian Chapin

Rep. Miller, George [D-CA-11] has introduced legislation to revise the OSHA penalty structure. There are some interesting changes in this legislation: Repeat Violations – Increased from $70,000 to $120,000 Serious Violations – OSHA has requested increase from $7,000 to $12,000. … Continue reading →

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IIAR 2 and IIAR 4 up for public review

Posted on November 25, 2013 by Brian Chapin

IIAR Standard 2 (Safety Standard for Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) and IIAR Standard 4 (Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) are available for public review on the IIAR website. While being an IIAR member … Continue reading →

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CSB Releases Safety Video on 2009 Fatal Blast at NDK Crystal – Animation Depicts Stress Corrosion Cracking; Vessels Were Not Inspected or Tested

Posted on November 14, 2013 by Brian Chapin

Today the CSB issued a report on a 2009 vessel failure that it blamed on Stress Corrosion Cracking. There are some interesting lessons to be learned about incident investigation in this report since the mechanism that led to the vessel’s … Continue reading →

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EPA goes after a cold storage, the real estate agent AND the customer leasing the space!

Posted on November 5, 2013 by Brian Chapin

Complainant issued a Compliance Order to Respondent, and also to Quirch Foods Caribbean, Corp., and Caparra Realty Associates, LLC ( “the Order”) pursuant to Section 1 13 of the Act regarding the Facility. The Order required these parties to perform … Continue reading →

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NRC Call – When is it necessary? When is it a good idea?

Posted on October 18, 2013 by Brian Chapin

Most people involved with Ammonia Refrigeration understand that if we have an unintentional release of ammonia in excess of 100 pounds over a 24hr period, we have to report it to the National Response Center (among others) immediately or face … Continue reading →

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Paying for PSM, California Style

Posted on October 15, 2013 by Brian Chapin

The state of California is having some trouble funding their oversight of their state PSM rule: CalARP. Don’t worry though, they have a solution… The Department of Industrial Relations, Division of Occupational Safety and Health (DOSH) is proposing to adopt emergency … Continue reading →

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How do I deal with recommendations to my program?

Posted on September 29, 2013 by Brian Chapin

You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading →

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