OSHA becoming more Educated with Ammonia Refrigeration

OSHA becoming more Educated with Ammonia Refrigeration

“Knowledge will bring the opportunity to make a difference” –  Claire Fagin once said.  It all starts with education, applied through a hands on experience, then one may attain what is known as wisdom.  OSHA will be bringing a new perspective to looking at a mechanical refrigeration systems.  It has happened to all of us at one time in our career when a light switch […]

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RAGAGEP and 16 Considerations

RAGAGEP and 16 Considerations

Enforcement Considerations Under 1910.119, employers select the RAGAGEP with which their equipment and procedures must comply. In evaluating RAGAGEP compliance, CSHOs should be aware of a number of potential issues: There may be multiple RAGAGEP that apply to a specific process. For example, American Petroleum Institute (API), RP 520 Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries Part II – Installation, and International Standards […]

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Ask, Wait, and See

Ask, Wait, and See

For over two decades we have developed and implemented some of the finest PSM/RMP programs across the country.  Last time we checked there were over 7,500 locations that had RMP due to over 10,000 lbs of ammonia.  There were only 14,500 location in the same time period that had submitted RMPs for the 140+ chemicals.  GCAP has always said over half the PSM/RMP in the […]

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Blocked In

Blocked In

In this accident investigated by the CSB (Chemical Safety Board) there is so much an ammonia refrigeration and PSM/RMP covered process can relate too to improve the safety of your own process and the safety program that encompasses it. Over-pressure Protection Process Hazard  Analysis Management of Change Pre-Startup Safety Review Operating Procedures Hierarchy of Controls Process Safety Cultural Blocked In

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I am Grandfathered

I am Grandfathered

Since the advent of government enforcement many have probably said / defended / or heard that they are grandfathered in.  No different when it comes to PSM RMP implementation and of that the best practices we know as RAGAGEP.  When some says their grandfathered to a particular standard, we like to say show me the letter from the agencies that have the ability to give […]

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Should vs Shall

Should vs Shall

“Shall” and “Should” in RAGAGEP “Shall,” “must,” or similar language used in RAGAGEP reflects the developer’s view that the practice is a mandatory minimum requirement to control a hazard. Similarly, “shall not,” “prohibited,” or similar language references or describes unacceptable approaches or practices. If an employer deviates from an applicable “shall” or “shall not” requirement in the employer’s adopted RAGAGEP, OSHA will presume a violation. […]

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ASHRAE 15 & 34

ASHRAE 15 & 34

The 2016 editions of ASHRAE’s major refrigerants-related standards have been published as a package with 30 new refrigerants and refrigerant blends added. ANSI/ASHRAE 15, Safety Standard for Refrigeration Systems, and its sister standard, ANSI/ASHRAE 34, Designation and Safety Classification of Refrigerants, constitute a complete set of requirements for the safe design, construction and application of refrigeration systems used in a wide variety of residential, commercial […]

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How Long Do We Have?

How Long Do We Have?

EPA has established the following dates for facility owners and operators to comply with the revised rule requirements: Don’t let these pronounced dates sneak up on you. Comply with emergency response coordination activities within one year of the effective date of the final rule; Within three years of when the owner or operator determines that the facility is subject to the emergency response program requirements […]

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EPA and its New RMP Final Rule

EPA and its New RMP Final Rule

As expected and predicted that would take place before the change over of presidency, EPA announced their new final rule for what we call RMP known as 40 CFR 68.  What we wait to still see is what will OSHA propose and when? According to EPA, The amendments are intended to: Address and improve accident prevention program elements; Enhance the emergency preparedness requirements; Ensure LEPCs […]

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OSHA PSM Document Request

OSHA PSM Document Request

Here we have an example, from our brother in laws facility, of what regulatory agencies are requesting as a ChemNEP document request. Organizations, and the adept PSM pros they hire, have become more effective and efficient in responses to requests that once left industry pros spinning for traction. But just as it always has, iron sharpens iron, and those making the requests have grown in […]

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