-
Recent Posts
Recent Comments
- What the Ammonia refrigeration industry can learn from West, TX | TAO Compliance – PSM News for Ammonia Refrigeration on West Texas Damage Photos
- Resource Compliance » Overview of the DHS CFATS Regulation on Did you get a DHS – CFATS/CSAT Top Screen letter?
- FUD in the news! | TAO Compliance – PSM News for Ammonia Refrigeration on West Texas Damage Photos
- FUD in the news! | TAO Compliance – PSM News for Ammonia Refrigeration on Texas Ammonia Explosion Coverage
- OSHA is going to have a field day in 2016 | TAO Compliance – PSM News for Ammonia Refrigeration on Chicago Jewel’s Citation on Operating Procedures and PSI
Archives
- June 2021
- August 2019
- October 2018
- August 2018
- July 2018
- May 2018
- March 2018
- February 2018
- November 2017
- October 2017
- August 2017
- July 2017
- April 2017
- March 2017
- February 2017
- January 2017
- December 2016
- October 2016
- September 2016
- August 2016
- July 2016
- June 2016
- May 2016
- January 2016
- December 2015
- November 2015
- June 2015
- May 2015
- March 2015
- January 2015
- October 2014
- August 2014
- July 2014
- May 2014
- April 2014
- March 2014
- February 2014
- November 2013
- October 2013
- September 2013
- August 2013
- July 2013
- June 2013
- May 2013
- April 2013
- February 2013
- November 2012
- October 2012
- September 2012
- August 2012
- July 2012
- June 2012
- May 2012
- April 2012
- March 2012
- February 2012
- January 2012
- December 2011
- November 2011
- September 2011
- August 2011
- July 2011
- May 2011
- April 2011
- March 2011
- February 2011
- January 2011
- December 2010
- November 2010
- October 2010
- September 2010
- August 2010
- July 2010
Categories
- Community Involvement
- Compliance
- Contractors
- CSB
- Culture
- DHS
- EPA
- General Duty
- General Information
- Good Engineering Practices
- IIAR
- Incidents
- Inspections
- LOTO
- Management of Change
- Mechanical Integrity
- NEP
- Oddities
- Operator Training
- OSHA
- PPE
- RETA
- SOP Development
- SPCC
- Standardization
- System Optimization
- Thermography
- Tier II
- Training
- Uncategorized
Category Archives: Management of Change
Is a condenser change a Replacement in Kind?
The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading
Posted in Compliance, EPA, IIAR, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RAGAGEP, RMP
Comments Off on Is a condenser change a Replacement in Kind?
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
Comments Off on RAGAGEP Hierarchy in Application – A worked example
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
Comments Off on Management Of Change (MOC) for Personnel
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
Comments Off on Why does my PSM program make me review the PHA during any equipment/facility MOC?
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
Comments Off on Misunderstanding MOC
Here’s a change that doesn’t require a Formal MOC!
I am sure many of my PSM friends have noticed my lethargic posting rate at the blog over the past year or so. I’ve been running all around the country helping people with their PSM programs through Audits, PHA’s and … Continue reading
Posted in General Information, Management of Change
Tagged Biography
Comments Off on Here’s a change that doesn’t require a Formal MOC!
A debate on Management of Change
Recently a group of safety yahoos got together to discuss a situation: You have a freezer with racking. The racking needs to be removed for XXXX reason. You hire a contractor to do the job. You evaluate and train the … Continue reading
Posted in Contractors, General Information, Incidents, Management of Change, NEP, Standardization, System Optimization
Tagged Contractors, Incidents, OSHA, PSM, RMP, Standardization
Comments Off on A debate on Management of Change
OSHA cites Kraft in Madison Wisconsin
MADISON, Wis. – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited Kraft Foods Inc. for 12 serious and one other-than-serious safety violation at a facility of its subsidiary, Oscar Meyer, in Madison. Proposed fines total $75,000. … Continue reading
Posted in Compliance, Management of Change
Tagged Fines, OSHA
Comments Off on OSHA cites Kraft in Madison Wisconsin