Category Archives: Compliance

Regulatory Compliance

OSHA Memo on RAGAGEP

Posted on June 11, 2015 by Brian Chapin

Link to OSHA publication – Highlights (underline) are mine. Note that they reference the CCPS again. The really good stuff is at the bottom in the notes to the inspectors.   MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY … Continue reading →

Posted in Compliance, NEP, OSHA | Tagged , , , , | Comments Off on OSHA Memo on RAGAGEP

Opinion: Why many Safety Programs fail to get results

Posted on May 3, 2015 by Brian Chapin

The question that vexed me Over the past few years as a traveling PSM auditor I was exposed to hundreds of different safety programs. There were small, flat organizations with dozens of workers and large international conglomerates with thousands of … Continue reading →

Posted in Compliance, Culture, System Optimization | Tagged , , , | Comments Off on Opinion: Why many Safety Programs fail to get results

Shock to the system

Posted on March 27, 2015 by Brian Chapin

The CSB just released a video on the August 23, 2010 Alabama ammonia release. While not perfect, it is a worthwhile video to watch as it might just make you question how you should deal with the type of power-failure issues … Continue reading →

Posted in Community Involvement, Compliance, CSB, Good Engineering Practices, Incidents | Tagged , , , , | Comments Off on Shock to the system

Region 7 Ammonia Safety Day

Posted on March 18, 2015 by Brian Chapin

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 , , , , , | Comments Off on Region 7 Ammonia Safety Day

Relief Systems – Understanding Design and Design Basis

Posted on October 3, 2014 by Brian Chapin

In compliance audits all over the country, we’re finding that the requirements for documenting the relief systems are not being met in many PSM programs. How bad is the situation? About 1/3rd of the relief documentation we see shows that … Continue reading →

Posted in Compliance, Good Engineering Practices | Tagged , , | Comments Off on Relief Systems – Understanding Design and Design Basis

What’s the deal with Valve torque?

Posted on August 28, 2014 by Brian Chapin

A common question I get is whether or not flanged and bonneted valves need to be torqued when they are installed. Unfortunately, many of these questions are due to OSHA citations – Ideally you want to answer this question BEFORE the … Continue reading →

Posted in Compliance, Contractors, Good Engineering Practices, Mechanical Integrity | Tagged , | Comments Off on What’s the deal with Valve torque?

EPA RMP Executive Summary

Posted on July 2, 2014 by Brian Chapin

As part of GCAP’s PSM course, we pull the publically available RMP from RTKnet.org for each facility in the class. We’ve seem some strange things in the Executive Summary and wanted to share some guidance on what exactly should and should not … Continue reading →

Posted in Compliance, EPA | Tagged , | Comments Off on EPA RMP Executive Summary

Lessons Shared #2 – “That policy is for other people…”

Posted on May 6, 2014 by Brian Chapin

This post is part of a series on Lessons Shared… This incident is about a common problem in PSM plants: Some people don’t think the rules apply to them. This story is from a friend who works as a refrigeration … Continue reading →

Posted in Compliance, Culture, Incidents | Tagged , , | Comments Off on Lessons Shared #2 – “That policy is for other people…”

$205,000 fine for dumping 40 pounds of ammonia

Posted on March 12, 2014 by Brian Chapin

Kodiak fish processor North Pacific Seafoods pleaded guilty Tuesday in federal court to illegally dumping ammonia into the Kodiak city sewer, while the processor’s chief engineer faces charges of his own. District Court Judge Ralph Beistline imposed $205,000 in criminal … Continue reading →

Posted in Community Involvement, Compliance, EPA, Incidents | Tagged , , | Comments Off on $205,000 fine for dumping 40 pounds of ammonia

Should you challenge OSHA citations?

Posted on February 3, 2014 by Brian Chapin

Will Kramer has written an excellent article on why you should challenge OSHA citations. Based on an analysis of the more than 57,000 citations listed in OSHA’s public inspection databases in 2012, employers achieved an average penalty reduction of 49% … Continue reading →

Posted in Compliance, OSHA | Tagged , | Comments Off on Should you challenge OSHA citations?