Category Archives: Compliance

Regulatory Compliance

What does OSHA think is the biggest concern in ammonia refrigeration components?

Posted on August 9, 2013 by Brian Chapin

I read a disturbing amount of OSHA documents through FOIA requests for research. About 99% of the stuff I read is pretty useless or already known to me from previous reading, but occasionally you come across something that wasn’t redacted … Continue reading →

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Interesting Times

Posted on August 1, 2013 by Brian Chapin

A wise man once said that it was a curse if someone said to you: “May you live in interesting times.” EXECUTIVE ORDER – – – – – – – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested … Continue reading →

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Five Year Independent Full Inspection

Posted on July 8, 2013 by Brian Chapin

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading →

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So, you need a PSM coordinator…

Posted on May 7, 2013 by Brian Chapin

The Situation: Several times a month I get a call from a recruiter or a facility that desperately needs to fill a PSM coordinator position. They quickly learn something that many people in our industry are unaware of – quality … Continue reading →

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Texas Ammonia Explosion Coverage

Posted on April 18, 2013 by Brian Chapin

Just a quick note – I hope to update this later. The explosion in Texas has caused some reporters to imply that the company’s RMP filing for Anhydrous Ammonia was inaccurate because the “Worst Case Scenario” didn’t include an explosion … Continue reading →

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EPA & Tyson agree to settle in a BIG way

Posted on April 5, 2013 by Brian Chapin

The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice announced a Clean Air Act (CAA) settlement with Tyson Foods, Inc. and several of its affiliate corporations to address threats of accidental chemical releases after anhydrous ammonia was … Continue reading →

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Are Oil Separators a Confined Space?

Posted on February 8, 2013 by Brian Chapin

Quite a few people have been reporting that OSHA inspectors and consultants are making an issue of people not classifying their compressor oil separators as a confined space. This is vexing because unless your oil separators are “large enough and … Continue reading →

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The real cost of an OSHA/EPA fine isn’t the check you write

Posted on November 15, 2012 by Brian Chapin

Sure, it’s painful to write a check to pay fines, but if you think that fine is the cost of OSHA/EPA non-compliance, you’re in for a rude awakening. The real cost of a fine from OSHA or the EPA isn’t … Continue reading →

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Maximum Intended Inventory (1910.119(d)(2)(i)(C))

Posted on October 18, 2012 by Brian Chapin

Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you … Continue reading →

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What should you do if you get a notice of an EPA Risk Management Program inspection?

Posted on September 28, 2012 by Brian Chapin

Depending on your area you may get anywhere from five days up to six weeks notice for a scheduled  inspection from the EPA. You aren’t going to create a compliant, living PSM/RMP program in that time frame but there are … Continue reading →

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