Category Archives: OSHA

Is a condenser change a Replacement in Kind?

Posted on July 18, 2018 by Brian Chapin

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 , , , , , | Comments Off on Is a condenser change a Replacement in Kind?

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 →

Posted in Culture, General Information, Good Engineering Practices, Incidents, OSHA, System Optimization | Tagged , , , , , | Comments Off on Learning from Failure

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 →

Posted in Compliance, General Duty, General Information, NEP, OSHA | Tagged , , , | Comments Off on What you need to know about Repeat Citations

RAGAGEP Hierarchy in Application – A worked example

Posted on October 10, 2017 by Brian Chapin

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 , , , , , | Comments Off on RAGAGEP Hierarchy in Application – A worked example

What training does my refrigeration operator need?

Posted on July 11, 2017 by Brian Chapin

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 , , , , , , | Comments Off on What training does my refrigeration operator need?

Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP

Posted on March 10, 2017 by Brian Chapin

You may have recently heard a headline that OSHA is losing their right to cite you for something that happened more than six months ago. I’ve heard a disturbing amount of people tell me that this means that many PSM issues … Continue reading →

Posted in Compliance, Inspections, OSHA | Tagged , , , , | Comments Off on Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP

How to get Willful OSHA Citations & Fines

Posted on February 16, 2017 by Brian Chapin

The incident we are discussing today is from a recent ruling in the United States Court of Appeals, Seventh Circuit where they recently denied a petition for review in the case of “DANA CONTAINER, INC. v. SECRETARY OF LABOR.” While this … Continue reading →

Posted in Community Involvement, Compliance, OSHA | Tagged , | Comments Off on How to get Willful OSHA Citations & Fines

Why does my PSM program make me review the PHA during any equipment/facility MOC?

Posted on February 13, 2017 by Brian Chapin

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 , , , , | Comments Off on Why does my PSM program make me review the PHA during any equipment/facility MOC?

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 →

Posted in Compliance, General Information, Inspections, Mechanical Integrity, NEP, Operator Training, OSHA, SOP Development, Training | Tagged , , , , , , , , | Comments Off on What questions should I expect during a ChemNEP inspection?

OSHA replaces the ChemNEP inspection protocol

Posted on January 22, 2017 by Brian Chapin

Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading →

Posted in Compliance, EPA, OSHA | Tagged , , , , | Comments Off on OSHA replaces the ChemNEP inspection protocol