Category Archives: Compliance

Regulatory Compliance

Merry Christmas from the EPA!

Posted on December 22, 2016 by Brian Chapin

Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … 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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Appeals Court upholds Contractor PSM Citations

Posted on August 25, 2016 by Brian Chapin

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 →

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OSHA increases fine amounts by 78%!

Posted on July 22, 2016 by Brian Chapin

In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. The Department of Labor is adjusting penalties for its agencies, including the Occupational Safety and Health Administration (OSHA). OSHA’s maximum penalties, which … Continue reading →

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Who is Certified / Qualified to Train Process Operators?

Posted on June 23, 2016 by Brian Chapin

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 →

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Misunderstanding MOC

Posted on May 9, 2016 by Brian Chapin

Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading →

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What the Ammonia refrigeration industry can learn from West, TX

Posted on January 29, 2016 by Brian Chapin

Last night I attended the CSB Public Meeting in Waco, TX concerning the 2013 West, TX Ammonia Nitrate explosion. The purpose of the meeting was to release their report on the incident. The explosion resulted in 15 fatalities and 260 … Continue reading →

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A little memo with some very big implications

Posted on December 22, 2015 by Brian Chapin

  Memo of Understanding between the DOL and DOJ: The U.S. Department of Labor (DOL) and the U.S. Department of Justice (DOJ), recognizing the importance of ensuring the health and safety of America’s workforce, enter into this memorandum of understanding … Continue reading →

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OSHA fines to rise 80%?

Posted on November 9, 2015 by Brian Chapin

OSHA Defense Report says that the  “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” gives OSHA the green light to increase penalty amounts to catch up with cost of living adjustments since the last time OSHA’s civil penalties … Continue reading →

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