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Tag Archives: NEP
What you need to know about Repeat Citations
First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading
Posted in Compliance, General Duty, General Information, NEP, OSHA
Tagged Fines, NEP, OSHA, PSM
Comments Off on What you need to know about Repeat Citations
What questions should I expect during a ChemNEP inspection?
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
Posted in Compliance, General Information, Inspections, Mechanical Integrity, NEP, Operator Training, OSHA, SOP Development, Training
Tagged Fines, Lessons Learned, Mechanical Integrity, NEP, Operator Training, OSHA, PSM, RAGAGEP, Standardization
Comments Off on What questions should I expect during a ChemNEP inspection?
OSHA replaces the ChemNEP inspection protocol
Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading
When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?
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
Posted in Compliance, General Information, Good Engineering Practices, NEP
Tagged Incidents, Lessons Learned, NEP, PHA
Comments Off on When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?
OSHA increases fine amounts by 78%!
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
Posted in Compliance, General Information, Inspections, NEP, OSHA
Tagged Fines, NEP, OSHA, PSM
Comments Off on OSHA increases fine amounts by 78%!
OSHA Memo on RAGAGEP
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
OSHA is going to have a field day in 2016
The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading
Posted in Compliance, Inspections, NEP, SOP Development, Standardization
Tagged NEP, OSHA, PSM, RAGAGEP
Comments Off on OSHA is going to have a field day in 2016
OSHA to focus on difficult inspections (like PSM) in 2014
Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading
The three levels of PSM Compliance…
I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading
