NEP Questions: Article 4 of 4: Training

NEP Questions: Article 4 of 4: Training

Part 4 of 4: NEP Questions? GCAP has been honored to release National Emphasis Program questions through RETA.  The article is questions based upon the PSM/RMP element we know as training.  We encourage you to look at your own PSM/RMP programs and evaluate your effective tools for implementation. 1910.119(g) Training: Questions for Maintenance/Operating Personnel Have you been formally trained in all the operating procedures of […]

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EPA Update for Region 7

EPA Update for Region 7

Our safety day in Kansas City, Kansas this last week was another great event.  We had over 250 different participants and 29 vendors representing.  This year Jodi Harper of Region 7 EPA gave us the EPA Update.  It was interesting to see the citations rank by most recent in element to what we have that has been released through GCAP and others by OSHA. EPA […]

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Compliance Audits: Compliance Strategy

Compliance Audits: Compliance Strategy

A well conducted audit will investigate every facet of your PSM system; both its structure and its implementation. The audit itself should consisted of the following activities: Extensive review of PSM/RMP documentation provided by the facility Interviews with operating staff – The interviews with hourly personnel were conducted primarily to confirm written policies and procedures with actual practice. Tours of the covered processes – Physical […]

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EPA is Not Slowing Down

EPA is Not Slowing Down

In the last several weeks several closed violations have been agreed upon between companies and EPA.  Please don’t forget that our industry in under scrutiny by the US EPA. Things to consider: Installation to Manufactures recommendations and torque specifications Failure to replace recalled PRV’s  Training and RAGAGEP PHA and RAGAGEP Pipe Labeling and Pipe Insulation Worst Case Release and Mechanical Integrity  Wrong Person Opening Wrong […]

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IIAR 2: Under Public Review

IIAR 2: Under Public Review

IIAR 2 2014: Addendum A; is under public review.  Last year IIAR 2 2014 was released and now is under a public review for its first addendum.  It is the Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems is now open.  The public review will be conducted for 45 days from March 24, 2017 through May 8, 2017. Comments must be submitted to the International […]

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EPA Pushes Back RMP Update!

EPA Pushes Back RMP Update!

The EPA is proposing to delay the effective date of the final rule that amends the Risk Management Program regulations under the Clean Air Act published in the Federal Register on January 13, 2017. On March 16, 2017, the EPA published in the Federal Register a stay and delay of the effective date pending reconsideration to June 19, 2017. The EPA is proposing to further […]

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Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration System

Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration System

If any of you have ever heard of IIAR Bulletin 110 it was first written in 1993, and has had no major changes or updates since.  Bulletin 110 was IIAR’s approach to what they believed should be involved with Mechanical Integrity.  In that RAGAGEP document, it suggested things such as; every 24-72 hours operational inspections test all safety cutouts bi-annually independent inspections by competent individuals […]

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EPA and Courtesy Calls

EPA and Courtesy Calls

Over the last week, we have received several phone calls/emails from past student whom have received phone calls from the EPA.  This has been taking place in EPA region 5.  These EPA inspectors/employees have asked several question in reference to documentation regarding up-charges to the existing mechanical refrigeration system in the last 5 years and if any of them were over 10,000 lbs.  We have […]

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Part 3 of 4: NEP Questions PHA

Part 3 of 4: NEP Questions PHA

Part 3 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 […]

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Ammonia Safety Day

Ammonia Safety Day

Kansas City 9th Annual Region 7 Ammonia Safety Day June 1, 2017 @ Kansas City Community College @ Kansas City, KS $35.00 per attendee $400.00 per exhibitor Thank you for the continued support of the Kansas City Safety Day.  This event is designed for continual growth and new topics each year.  If you are in operations, safety, compliance, supervisor, technicians, mechanic, or manager this event […]

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