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Category Archives: EPA
EPA RMP update “Delay” rule vacated by DC District Court
EPA retains authority under Section 7412(r)(7) to substantively amend the programmatic requirements of the Chemical Disaster Rule, and pursuant to that authority, revise its effective and compliance dates, subject to arbitrary and capricious review. . . . the agency must … Continue reading
Posted in Community Involvement, EPA
Tagged EPA, RMP
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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?
Yet another update on the RMP Updates!
Today, EPA’s Administrator, E. Scott Pruitt, signed a new proposed rule, further changing the Obama-era EPA’s proposed changes and the EPA is submitting that for publication in the Federal Register (FR). Basically, it outlines two proposals for the Obama-era EPA’s … Continue reading
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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PHA Worksheets Template updated
The Template What-If / Checklist worksheet used to guide PHA Studies has been modified. The Identification and Review of Past Incidents section has been renumbered with some new questions concerning the performance of the Incident Investigation element added before the example / … Continue reading
Posted in Compliance, EPA, Standardization
Tagged PHA, Process Hazard Analysis
Comments Off on PHA Worksheets Template updated
What training does my refrigeration operator need?
Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation. Understanding the requirements of PSM/RMP training for Operators The Training element in PSM (1910.119(g)) and … Continue reading
Posted in EPA, Operator Training, OSHA, Training
Tagged Employee Involvement, EPA, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
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Updated RMP Rule likely delayed until at least 2019!
I’ve delayed updating the templates that reflect the proposed EPA RMP changes for several reasons. Our patience has been well-rewarded: The EPA has proposed to further delay the effective date to February 19, 2019. This action would allow the Agency time … Continue reading
Posted in Compliance, EPA
Tagged EPA, RMP
Comments Off on Updated RMP Rule likely delayed until at least 2019!
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?
Update: Congressional Review Act & RMP Rule
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
Posted in EPA, General Information
Tagged EPA, RMP
Comments Off on Update: Congressional Review Act & RMP Rule
While there are Executive Branch delays to the EPA’s new RMP updates, another possibility is that congress can use the Congressional Review Act to nullify the changes. This week, a group of associations joined in a letter requesting exactly that. Multi-Association … Continue reading
