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Tag Archives: PSM
Management Of Change (MOC) for Personnel
In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading
Posted in Compliance, Management of Change, System Optimization
Tagged Management of Change, PSM, RMP
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Outsourcing your Contractor Selection Process – Can it be done?
Over the past few years we’ve seen an increase in the number of companies that use a 3rd party service to qualify their contractors. Often, these services screen the prospective contractor for their safety record / programs, insurance history / … Continue reading
Posted in Compliance, Contractors
Tagged Contractors, PSM, RMP
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Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
You may have recently heard a headline that OSHA is losing their right to cite you for something that happened more than six months ago. I’ve heard a disturbing amount of people tell me that this means that many PSM issues … Continue reading
Posted in Compliance, Inspections, OSHA
Tagged EPA, Fines, OSHA, PSM, RMP
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Why does my PSM program make me review the PHA during any equipment/facility MOC?
Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RMP
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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
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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
Appeals Court upholds Contractor PSM Citations
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
Posted in Compliance, Contractors, Inspections, Mechanical Integrity, Operator Training, OSHA
Tagged Contractors, Fines, Mechanical Integrity, PSM
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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
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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
Region 7 Ammonia Safety Day
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 CSB, EPA, Operator Training, OSHA, PSM, RMP
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