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Tag Archives: RMP
What training does my refrigeration operator need?
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
Posted in EPA, Operator Training, OSHA, Training
Tagged Employee Involvement, EPA, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
Comments Off on What training does my refrigeration operator need?
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
Comments Off on Management Of Change (MOC) for Personnel
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
Comments Off on Outsourcing your Contractor Selection Process – Can it be done?
Updated RMP Rule likely delayed until at least 2019!
I’ve delayed updating the templates that reflect the proposed EPA RMP changes for several reasons. Our patience has been well-rewarded: The EPA has proposed to further delay the effective date to February 19, 2019. This action would allow the Agency time … Continue reading
Posted in Compliance, EPA
Tagged EPA, RMP
Comments Off on Updated RMP Rule likely delayed until at least 2019!
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
Comments Off on Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
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
Comments Off on Why does my PSM program make me review the PHA during any equipment/facility MOC?
Update: Congressional Review Act & RMP Rule
The EPA’s RMP Rule update is NOT part of the initial 5 regulations that the House has decided to disapprove via the Congressional Review Act. (Bloomberg) …and here it is! US Rep. Markwayne Mullin (R-Okla.) introduced Congressional Review Act … Continue reading
Posted in EPA, General Information
Tagged EPA, RMP
Comments Off on Update: Congressional Review Act & RMP Rule
While there are Executive Branch delays to the EPA’s new RMP updates, another possibility is that congress can use the Congressional Review Act to nullify the changes. This week, a group of associations joined in a letter requesting exactly that. Multi-Association … Continue reading
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
Merry Christmas from the EPA!
Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … Continue reading
