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Category Archives: Good Engineering Practices
Yeah, but No – Compliance vs. Safety
Often, compliance and safety go hand-in-hand. This leads us to believe they are the same thing. Occasionally they are not; and when that’s the case, it is our duty to place SAFETY above Compliance. Relief Piping Termination – A worked … Continue reading
Posted in General Information, Good Engineering Practices
Tagged PSM, RAGAGEP, RMP
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IIAR 2-2014, Addendum A Third Public Review
The IIAR has announced a 3rd Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems. This brings some interesting changes to IIAR 2 . Two of these proposed changes are : Clearing up the … Continue reading
Posted in Compliance, Good Engineering Practices, IIAR
Tagged RAGAGEP
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IIAR 6 Public Review #3
Make your opinion known BEFORE the changes go final! IIAR 6 continues its development. This document will replace IIAR Bulletin 110 (among others) and will be very important. The current review only lists changes since Public Review #2. To: IIAR Members … Continue reading
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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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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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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Why does my PSM program make me review the PHA during any equipment/facility MOC?
Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RMP
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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
Posted in Compliance, Good Engineering Practices, SOP Development, Standardization
Tagged RAGAGEP, SOP, Standardization
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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
Posted in Compliance, General Information, Good Engineering Practices, NEP
Tagged Incidents, Lessons Learned, NEP, PHA
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Misunderstanding MOC
Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading
Posted in Compliance, Good Engineering Practices, Management of Change
Tagged EPA, Management of Change, OSHA
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