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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RMP v/s CalARP Title 19

RMP v/s CalARP Title 19

As many professionals within the PSM/RMP industry understand the nuances of personal interpretation by what is considered to many as being a very black and white federal law, there are still certain obstacles one must overcome, should a should be considered a SHALL, are all SHALLs actually required, so on and so forth. This is not including what is considered to be the Mecca of […]

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40 CFR 68.200 Recordkeeping

40 CFR 68.200 Recordkeeping

Well we learned something new last week and another item to the table the makes EPA’s RMP a little different to OSHA’s PSM.  Most of us know all the time tables associated with elements of PSM/RMP, but for myself reading 40 CFR 68.200 was a change in how I thought I knew the regulation. “The owner or operator shall maintain records supporting the implementation of […]

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Part 2 of 4: NEP Questions?

Part 2 of 4: NEP Questions?

Part 2 of 4: NEP Questions? The Process Safety Management (PSM) regulations is over 20 years old and the National Emphasis Program (NEP) is nearing five years, and the regulators are not slowing down. Recent alerts from EPA (anhydrous ammonia at refrigeration facilities under scrutiny) and OSHA (RAGAGEP in PSM enforcement) show their passion for compliance. President Obama has signed executive orders and mandated re-writes […]

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Part 1 of 4: NEP Questions?

Part 1 of 4: NEP Questions?

PSM regulation is over 20 years old and the National Emphasis Program running on 5 years, the regulators are not slowing down.  Recent alerts from EPA (Anhydrous Ammonia at Refrigeration Facilities under Scrutiny) and OSHA (RAGAGEP in PSM Enforcement) show their pursuant for compliance.  Obama has signed chemical executive orders and mandated re-writes of PSM/RMP regulations occurring now.  End users in our industry have to […]

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OSHA Region 7 PSM Update 2016

OSHA Region 7 PSM Update 2016

Region 7 OSHA gave the PSM update for 2016 @ GCAP’s 8th Annual Ammonia Safety Day this month. Much emphasis was placed on; RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) such as IIAR, ASHRAE, Center for Chemical Process Safety (CCPS), and others. Retail Exemption Changes Re-write of 1910.119 Emergency Planning and Response View the presentation by clicking this link GCAP OSHA PSM 2016 Update Region […]

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