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 Read more

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 Read more

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 Read more

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 Read more

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 Read more

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 Read more

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 Read more

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 Read more

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 Read more