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Category Archives: NEP
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
Posted in Compliance, EPA, General Information, Good Engineering Practices, Mechanical Integrity, NEP, OSHA
Tagged Fines, Mechanical Integrity, RAGAGEP
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Maximum Intended Inventory (1910.119(d)(2)(i)(C))
Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, NEP
Tagged EPA, OSHA, PSM, RAGAGEP, RMP
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PSM Citations – A year broken down by Industrial Classification
OSHA has posted a breakdown of PSM citations so you can compare industry groups that have been cited by Federal OSHA during the period October 2010 through September 2011. I plugged this data into Excel and ran some numbers between … Continue reading
Posted in Compliance, General Information, NEP
Tagged Fines, OSHA, PSM
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Pressure Relief Valves – The Five Year Replacement Interval
There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading
Posted in Compliance, Good Engineering Practices, Mechanical Integrity, NEP
Tagged Mechanical Integrity, OSHA, PSM, RAGAGEP
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Two recent NH3 Refrigeration Fines
US Labor Department’s OSHA cites Rochester, NY, milk products manufacturer, proposes more than $200,000 in fines, for repeat and serious hazards. . $153k of the citations are Repeat citations. . Failing to address the hazards of oil draining in the PHA. … Continue reading
Posted in Compliance, General Information, Good Engineering Practices, NEP
Tagged Fines, OSHA, PSM, RAGAGEP, SOP
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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
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PSM Covered Chemical Facilities National Emphasis Program goes NATIONWIDE!
OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (See Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119). These incidents spurred broad recognition that releases of highly hazardous chemicals … Continue reading
Posted in Compliance, NEP
Tagged Fines, OSHA, PSM
Comments Off on PSM Covered Chemical Facilities National Emphasis Program goes NATIONWIDE!
