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
“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
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
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
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 Read more
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
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
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
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 Read more
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 Read more
