Category Archives: General Information

General Information

Site Update

Posted on June 19, 2021 by Brian Chapin

Almost all my new posts are on RCE Chill. I only post things here that are controversial personal opinions. If you are looking for information on the OSPSM project, an Open-Source resource for PSM and Safety Templates please contact me. … Continue reading →

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Yeah, but No – Compliance vs. Safety

Posted on August 27, 2019 by Brian Chapin

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 →

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Learning from Failure

Posted on May 17, 2018 by Brian Chapin

“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 →

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What you need to know about Repeat Citations

Posted on March 9, 2018 by Brian Chapin

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading →

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Why we changed our element “Guidelines” to be called “Written Plans”

Posted on July 28, 2017 by Brian Chapin

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading →

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What questions should I expect during a ChemNEP inspection?

Posted on February 6, 2017 by Brian Chapin

A friend in the industry recently went through an OSHA ChemNEP inspection on their NH3 Refrigeration System. Over the years, I’ve had the pleasure of working with many of their team members and have audited several of their facilities. They … Continue reading →

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Update: Congressional Review Act & RMP Rule

Posted on February 1, 2017 by Brian Chapin

The EPA’s RMP Rule update is NOT part of the initial 5 regulations that the House has decided to disapprove via the Congressional Review Act. (Bloomberg)   …and here it is! US Rep. Markwayne Mullin (R-Okla.) introduced Congressional Review Act … Continue reading →

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Pencil-Whipping can Kill

Posted on December 15, 2016 by Brian Chapin

What is it? Pencil-whipping is when you complete a form, record, or document without having performed the implied work or without supporting data or evidence. Here are some common examples in NH3 refrigeration: Completing “word orders” without conducting the work … Continue reading →

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When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?

Posted on September 9, 2016 by Brian Chapin

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 →

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DHS CFATS Top-Screen Update

Posted on September 1, 2016 by Brian Chapin

It looks like the DHS has finally got around to updating their Top-Screen program. Below is the email from them: ——————————————————————————– Subject: Enhanced CFATS Risk-Assessment Methodology and Upcoming Requirement to Submit CFATS Top-Screen From: “cfatsupdate” <[email protected]> Date: Tue, August 30, … Continue reading →

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