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OSHA vs. EPA

Of course, if you are covered under OSHA's PSM regulation you know that you are covered under the EPA's RMP regulation as well. I understand why most people focus on the PSM regulations - they are used to dealing with OSHA regulations that cover everything from PPE to Lockout/Tagout. Furthermore, if you follow the PSM regulations to the letter, you are essentially covering every single element of the RMP requirements but one.

What amazes me is the general lack of interest, or at least the minor importance that is usually placed by most safety professionals on the Risk Management Plan that is unique to the EPA regulations.

Here are the requested budgets for OSHA and the EPA for fiscal year 2009:

OSHA $501.7 million
EPA $7.14 billion

Now that you see the EPA has nearly 14 and a half times the budget, ask yourself a question: Which one of these agencies is more likely to have the resources to make my life miserable?

Please, take some time to review your EPA required Risk Management Plan.

Here are some things to think about:

Is your RMP management system up to date and are those managers keeping up with their responsibilities under the plan? Has this been audited and documented?

Has every incident that could have resulted in a catastrophic release been investigated and documented?

Have you updated your five year accident history?

Has anything happened that would alter the consequences or likely frequency of your catastrophic release scenarios?

Is your currently filed RMP up to date?

Fifteen Questions You Should Ask Any Potential ERP Software Supplier

Looking for Enterprise Resource Planning software? There is no lack of it out there and the costs of making the wrong decision can be staggering. In some research I came across this interesting white paper from Technology Group International that provides some sample questions to ask your prospective ERP software vendor.

1. Will you provide full source code in the price of the software?

2. Will you provide a risk-free trial period on the software during which we can return it for a full refund?

3. Is the software written in a commercially available development language which is still being enhanced and supported by the supplier?

4. What is the cost for the first and subsequent years’ maintenance with your software?

5. When a call is placed to your support organization, who is the first person we talk to and what is their background and experience with the software?

6. What is the average amount of time that lapses between a report of a non-mission critical bug and the ‘fix’ becoming available in the software?

7. How does your organization compare to other organizations in your industry relative to revenue per employee?

8. Does the system come with a fully integrated Warehouse Management System (WMS) as part of the software cost?

9. Does your software include Customer Relationship Management (CRM) functionality as a separate module?

10. Are there any restrictions as to which database, hardware platform, network, or operating system environment the software can run on?

11. What is the typical ratio you have historically seen amongst your customers of implementation cost to software cost?

12. What is the typical implementation time frame for a company of our size?

13. What is the methodology you use to track project progress vs. plan from both a work completed and a financial standpoint?

14. Will you provide a guaranteed maximum cost for any work you do for our organization?

15. What level of effort is required to install future upgrades of the software?


There is a separate page devoted to each question detailing why it is important and what type of answers you should be looking for. Obviously, this is written by a software company that is trying to sell ERP software, so they aren't going to be terribly unbiased. That said, these are all excellent questions that you will eventually wish you had asked if you initially fail to.

I've always been a big fan of Kaizen, and gathering the information for a succesful application can be a real problem. ERP software looks like it is slowly evolving into something that will really help those attempting Lean and CI (continuous improvement)/Kaizen approaches to streamline there processes.

Training Expo in Central Pennsylvania

Last year I attended the 2007 Central PA RETA Training Expo and felt it was well worth the time. This year it is scheduled for April 3rd, 2008

This is a one day event held at the Thaddeus Stevens College of Technology in Lancaster, PA at a cost of $10 per attendee including lunch.


Classes currently scheduled:

"Arc Flash & Equipment PM" by Mr. Todd Benincasa, EE, Premium Power Services

"PSM - Contractor Safety" by Mr. Cliff Jarrett, Compliance Officer, OSHA

"Re-Circulatory Air Door Technology" by Mr. Tim Buckley, HCR Inc.

"Verification & Removal of Contaminated NH3" by Mr. Grant Williams, AIR GAS,Inc.

"Motors 101" by Mr. William Kohr, Motor Technology, Inc.

"Halocarbon Screw Technology" by Mr. Jon Lazarow, CopelandBitzer, Inc.

"Vessel Design Function & Operation" byVirgil Jordan, RVS, Inc.

"Chemical Treatment to Stop Deterioration" by Mr. Andy Nowak, Condor Technology, Inc.

"Low Temp. Insulation" by Mr. Mike Irlbacher, Extol of Ohio, Inc.


There will also be a healthy selection of vendors there to peruse - last year I found personal portable ammonia detectors that we now use at two facilities.

I have been informed by the SEPA RETA Chairman that you do NOT have to be a RETA member to attend the event.

If you are anywhere near the Lancaster area (I'll be driving two hours to get there) please consider attending this event and/or sending your refrigeration personnel to it. This event can be documented as a PSM/RMP training exercise for plants covered by the PSM/RMP regulation.

Click Here to download the schedule of events and registration form.

Learn Refrigeration Theory

Lets say that you are new to industrial refrigeration, or refrigeration in general. What is the easiest way to get up to speed on this rather counter-intuitive topic?

Well, I read quite a few books on the subject but honestly nothing really clicked for me until I read the RETA 1 & RETA 2 books.

I pick up information fairly quickly and within 30 days of study and application of these texts I was able to troubleshoot about 95% of the industrial refrigeration problems I came across. It turns out that many people who work in industrial refrigeration simply do not understand the theory behind refrigeration.

I've even had long-time operators explain to me that "Theory is fine, but it just doesn't work in the real world." This kind of operator has usually been left to their own devices to limp along a system that just barely works. Worse yet, since they are constantly having to adjust and "fix" the system they are viewed as heroes by many in the organization.

Well, here is the truth: If, in your experience, the theory isn't applicable, then you do not understand the theory well enough.

Buy yourself a copy of the RETA 1&2 books. For a real treat, see which (if any) of your operators can pass the tests that come with the books.

p.s. Avoid the RETA 3&4 books - they are being rewritten and should be updated within the next year or so.

Good News. In a Weird Way

Anyone who stores significant amounts of Anhydrous Ammonia knows that there is a very real risk of your storage facility being targeted by people who want to steal it for use in methamphetamine. It looks like some of the more industrious narcotic dealers have created a way to make meth that might minimize that threat.

"...in place of anhydrous ammonia, the new recipe calls for using common garden fertilizer or the ammonium nitrate found in cold-pack compresses — both easy to buy or steal" --The Kalamazoo Gazette

While there is no joy in the fact that this makes meth manufacture easier, there is some small comfort in knowing it lowers the risk posed by some yahoo breaking into an ammonia system; something that usually results in a significant environmental release.

Useful Resources

I'll slowly add to the Useful Resources list on the right over the next few days, but the following are pretty good places to bookmark as a start.

NH3 Info - Air Liquide has an excellent page with all the basic Anhydrous Ammonia properties you will likely ever need.

Refrigeration Engineers NH3 forum - A good place to start for newcomers to ammonia equipment troubleshooting.

Refrigeration Engineers and Technicians Association (RETA) - If you have the opportunity to join your local RETA chapter, I would highly recommend it. They also have a fairly decent online training program for your maintenance personnel.

OSHA's PSM - Occupational Safety and Health Administration's PSM guidance

EPA's RMP - Environmental Protection Agency's RMP guidance.

DHS CSAT - Department of Homeland Security's Chemical Security Anti-Terrorism Standard guidance.

Greetings

I work for a fairly large company implementing a Process Safety Management / Risk Management Program for three Ammonia refrigeration systems.

There are not a whole lot of people who work in this field and I thought that there might be some use in posting the information, strategies, observations and ideas I come across in attempting to create, maintain and implement a successful and compliant PSM/RM program.

If you are not in this field, there isn't much of interest you will find here... Unless of course you have trouble sleeping.