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Tag Archives: RAGAGEP
Maximum Intended Inventory (1910.119(d)(2)(i)(C))
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
Posted in Compliance, EPA, Good Engineering Practices, NEP
Tagged EPA, OSHA, PSM, RAGAGEP, RMP
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Unclear on the concept…
This one starts simply enough: 1910.119(d)(3)(ii) The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices. In this case the citation is in regards to an MSA gas monitor that wasn’t … Continue reading
Pressure Relief Valves – The Five Year Replacement Interval
There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading
Posted in Compliance, Good Engineering Practices, Mechanical Integrity, NEP
Tagged Mechanical Integrity, OSHA, PSM, RAGAGEP
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Two recent NH3 Refrigeration Fines
US Labor Department’s OSHA cites Rochester, NY, milk products manufacturer, proposes more than $200,000 in fines, for repeat and serious hazards. . $153k of the citations are Repeat citations. . Failing to address the hazards of oil draining in the PHA. … Continue reading
Posted in Compliance, General Information, Good Engineering Practices, NEP
Tagged Fines, OSHA, PSM, RAGAGEP, SOP
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No NH3 Detection – General Duty Citation in store?
Most General Duty citations have nothing to do with Ammonia refrigeration but I’ve started to see a trend recently where processes that are not covered by PSM are being subject to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). The … Continue reading
Posted in Compliance, General Information
Tagged Fines, General Duty, OSHA, RAGAGEP
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Torque Wrenches for Ammonia refrigeration valves
Yes, it really has come to this. Let’s start with a single citation… What equipment could this citation be concerning? Take a look at the compliance officer’s narrative: The officer went on to say in the OSHA 1-B Inspection worksheet: … Continue reading
Posted in Compliance, Mechanical Integrity, Oddities
Tagged Fines, Mechanical Integrity, OSHA, RAGAGEP
Comments Off on Torque Wrenches for Ammonia refrigeration valves
PSM NEP Podcast
I spent about two hours in the recording studio today with Jeremy Williams of GCAP. You can listen to the first part of our conversation on the NEP at GCAPCoolCast.com I’ve spent the last three weeks at GCAP re-working the … Continue reading
Posted in Compliance, General Information, Good Engineering Practices, Operator Training
Tagged EPA, Fines, Operator Training, OSHA, PSM, RAGAGEP, RMP
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PSM National Emphasis Program
If you aren’t familiar with the NEP (National Emphasis Program) currently going on in specific regions it would be well worth your time to get up to speed. Even if you have a top-notch program you’ve got a LOT of … Continue reading
Posted in Compliance, Good Engineering Practices, System Optimization
Tagged OSHA, PSM, RAGAGEP
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Tanner agrees to install $345,000 in ammonia leak detection systems
“While Tanner did take some actions to address the risks of an accidental release of ammonia at its facility in Rhode Island, Tanner failed to address the risk associated with the fact that its facility is not staffed except when … Continue reading
Posted in Community Involvement, Compliance, Good Engineering Practices, Incidents
Tagged EPA, Fines, Incidents, OSHA, PSM, RAGAGEP, RMP
Comments Off on Tanner agrees to install $345,000 in ammonia leak detection systems
Kent Ammonia Leak an Attempted Theft?
Usually the meth-makers pick on agricultural ammonia sources but they occasionally go to a cold storage as well: “The attempted theft of ammonia appears to be the cause of a leak Tuesday morning at the Washington Cold Storage facility in … Continue reading
Posted in Community Involvement, Good Engineering Practices, Incidents
Tagged RAGAGEP
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