Tag Archives: RMP

Yeah, but No – Compliance vs. Safety

Posted on August 27, 2019 by Brian Chapin

Often, compliance and safety go hand-in-hand. This leads us to believe they are the same thing. Occasionally they are not; and when that’s the case, it is our duty to place SAFETY above Compliance. Relief Piping Termination – A worked … Continue reading →

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EPA RMP update “Delay” rule vacated by DC District Court

Posted on August 17, 2018 by Brian Chapin

EPA retains authority under Section 7412(r)(7) to substantively amend the programmatic requirements of the Chemical Disaster Rule, and pursuant to that authority, revise its effective and compliance dates, subject to arbitrary and capricious review. . . . the agency must … Continue reading →

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Properly Addressing Findings / Recommendations

Posted on August 3, 2018 by Brian Chapin

Process Safety managers are often buried under a torrent of Findings and Recommendations from PSM/RMP elements such as Employee Participation (EP), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), Incident Investigations (II), and Compliance Audits (CA). In compliance audits over … Continue reading →

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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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Is a condenser change a Replacement in Kind?

Posted on July 18, 2018 by Brian Chapin

The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading →

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Yet another update on the RMP Updates!

Posted on May 17, 2018 by Brian Chapin

Today, EPA’s Administrator, E. Scott Pruitt, signed a new proposed rule, further changing the Obama-era EPA’s proposed changes and the EPA is submitting that for publication in the Federal Register (FR). Basically, it outlines two proposals for the Obama-era EPA’s … Continue reading →

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Learning from Failure

Posted on May 17, 2018 by Brian Chapin

“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading →

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IIAR 7 update now open for Public Review

Posted on November 10, 2017 by Brian Chapin

November 10th, 2017 To: IIAR Members Re: First (1st) Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems. A first (1st) public review of draft standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems is now … 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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Why we changed our element “Guidelines” to be called “Written Plans”

Posted on July 28, 2017 by Brian Chapin

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading →

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