Tag Archives: Mechanical Integrity

What can we learn from the Fernie Ammonia fatalities?

Posted on July 30, 2018 by Brian Chapin

The October 17th, 2017 Ammonia release in Fernie, BC resulted in three fatalities: On October 16, 2017, the curling brine chiller at the Fernie Memorial Arena was put back into operation after a seasonal shutdown. During the shutdown and seasonal … Continue reading →

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RAGAGEP Hierarchy in Application – A worked example

Posted on October 10, 2017 by Brian Chapin

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading →

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What training does my refrigeration operator need?

Posted on July 11, 2017 by Brian Chapin

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 →

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What questions should I expect during a ChemNEP inspection?

Posted on February 6, 2017 by Brian Chapin

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 →

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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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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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IRC releases their Mechanical Integrity Guidebook

Posted on July 21, 2016 by Brian Chapin

I’ve had my copy for a few months and think the IRC has done a fantastic job with this book. Here is the press-release: The IRC is pleased to announce the immediate availability of a new guidebook titled: Principles and … Continue reading →

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How do I deal with recommendations to my program?

Posted on September 29, 2013 by Brian Chapin

You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading →

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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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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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