Author Archives: Brian Chapin

About Brian Chapin

PSM / RMP Compliance Consultant

Do your Emergency Shut-down and Ventilation switches comply with IIAR2-2008b/IIAR5-2013, Appendix B?

IIAR5 was released just recently and a surprising number of people think that it introduces new requirements for emergency switches. The requirements themselves don’t differ from IIAR2-2008b – they are just laid out a little clearer in IIAR5, Appendix B: … Continue reading

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FUD in the news!

PSM people love their acronyms and we all have our favorites. One of mine is “FUD” or Fear, Uncertainty and Doubt. I generally use this acronym when discussing how the media reports stories about topics I am familiar with. It … Continue reading

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OSHA is going to have a field day in 2016

The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading

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OSHA to revise Palmer guidance on Hydrostatic Trapping

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading

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OSHA to focus on difficult inspections (like PSM) in 2014

Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading

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The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading

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Did you get a DHS – CFATS/CSAT Top Screen letter?

A lot of people got a letter recently from the Department of Homeland Security telling them that they have to file a CFATS Top-Screen. Unfortunately, some of you got this in error, but for those of you who actually still … Continue reading

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What does OSHA think is the biggest concern in ammonia refrigeration components?

I read a disturbing amount of OSHA documents through FOIA requests for research. About 99% of the stuff I read is pretty useless or already known to me from previous reading, but occasionally you come across something that wasn’t redacted … Continue reading

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Interesting Times

A wise man once said that it was a curse if someone said to you: “May you live in interesting times.” EXECUTIVE ORDER – – – – – – – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested … Continue reading

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Five Year Independent Full Inspection

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading

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