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Tag Archives: Standardization
Properly Addressing Findings / Recommendations
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
Posted in Compliance
Tagged PSM, RMP, Standardization
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IIAR 7 update now open for Public Review
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
Posted in Compliance, SOP Development, Standardization
Tagged PSM, RAGAGEP, RMP, SOP, Standardization
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Why we changed our element “Guidelines” to be called “Written Plans”
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
Posted in General Information, Standardization, System Optimization
Tagged PSM, RMP, Standardization
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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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2017 SOP Template Updates
The SOP reference element guideline and RESOP/ROSOP reference templates have been updated for 2017. The changes are basically broken into two groups: Continuous Improvement and IIAR 7. Continuous Improvement: As always, there are a lot of little change suggestions that … Continue reading
Posted in Compliance, Good Engineering Practices, SOP Development, Standardization
Tagged RAGAGEP, SOP, Standardization
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OSHA to revise Palmer guidance on Hydrostatic Trapping
OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading
Posted in Compliance, Good Engineering Practices, NEP
Tagged OSHA, PSM, RAGAGEP, Standardization
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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
How should I FIX a PSM program?
This might be one of the most common questions we’re asked: How do I resurrect a PSM program that has been neglected? Our answer is that you should deal with these broken programs no differently than if you are starting a … Continue reading
Posted in General Information, Standardization, System Optimization
Tagged General, PSM, RMP, Standardization
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A few links I wanted to share…
First up, S.K. Energy Consulting: There are some simple to understand articles on Floating Head Pressure and Optimizing Defrost. Check out the articles archives which contain almost 80 newsletters going back several years. Very informational site that I am surprised I … Continue reading
Posted in Compliance, General Information, Standardization, System Optimization
Tagged Efficiency, EPA, OSHA, PSM, RMP, Standardization
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Refresher Training
Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading
Posted in Compliance, Operator Training, System Optimization
Tagged Employee Involvement, EPA, Operator Training, OSHA, PSM, RMP, SOP, Standardization
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