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Category Archives: Operator Training
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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What questions should I expect during a ChemNEP inspection?
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 Fines, Lessons Learned, Mechanical Integrity, NEP, Operator Training, OSHA, PSM, RAGAGEP, Standardization
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Pencil-Whipping can Kill
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
Posted in Compliance, Culture, General Information, Incidents, Inspections, Mechanical Integrity, Operator Training, System Optimization
Tagged General, Incidents, Lessons Learned, Mechanical Integrity, Operator Training
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APR’s aren’t Magic
When I see people writing “Have a Full-Face APR (Air Purifying Respirator) nearby, within arm’s reach” in their Line/Equipment Opening (aka Line Break) procedures, my blood-pressure shoots through the roof. Yes, I know I am a rather excitable guy by … Continue reading
Posted in Culture, Incidents, Operator Training, Training
Tagged Incidents, Lessons Learned, Operator Training
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We’re all in this together
It was great to meet so many friends and colleagues in Las Vegas last week for RETA’s annual conference. While all business is about personal relationships, most people recognize that the Ammonia Refrigeration industry is a uniquely tight-knit group. I’ve … Continue reading
Posted in Culture, Operator Training
Tagged Employee Involvement, Lessons Learned, Operator Training
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Appeals Court upholds Contractor PSM Citations
A maintenance contractor that provides skilled labor to perform skilled labor, electrical and mechanical work was cited by OSHA for violations of the PSM standard after their employee was injured by a chemical release. OSHA threw the book at them … Continue reading
Posted in Compliance, Contractors, Inspections, Mechanical Integrity, Operator Training, OSHA
Tagged Contractors, Fines, Mechanical Integrity, PSM
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Who is Certified / Qualified to Train Process Operators?
Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading
Posted in Compliance, EPA, Operator Training, OSHA
Tagged EPA, Operator Training, OSHA
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Region 7 Ammonia Safety Day
If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading
Posted in Community Involvement, Compliance, CSB, EPA, Operator Training, OSHA
Tagged CSB, EPA, Operator Training, OSHA, PSM, RMP
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Lessons Shared #1 – “The Graveyards are full of Heroes”
I had to fight back tears the first time I read this NIOSH report. Having lived on a family farm for a short period, it was very easy for me to imagine the reaction of the people involved… A 43-year-old … Continue reading
Posted in Culture, Incidents, Operator Training, Training
Tagged Incidents, Lessons Learned, Operator Training
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Avoiding training requirements by hiring Contractors? Think again…
I am fortunate to have the opportunity to see a great many different ways to tackle PSM compliance as I audit PSM programs around the country. One thing that surprises me very often is how many people think that they … Continue reading
Posted in Compliance, Contractors, Operator Training, Training
Tagged Contractors, Operator Training, OSHA, PSM
Comments Off on Avoiding training requirements by hiring Contractors? Think again…