Brian Chapin, Compliance Services Manager
NOTE: This article is by my good friend and colleague Brian Chapin @ RC&E in Forth Worth, TX. In full disclosure, RC&E has been a corporate member for several years. Brian was gracious in allowing me to post his work directly at SAFTENG as some of you were having issues with the RCE Chill page. But for those of you who can access his articles at RCE Chill page, especially if you’re in the PSM/RMP Refrigeration arena, check out his library of work.
The whole country is facing a very difficult situation right now as we all deal with both the COVID-19 disease and the effects of government’s response to it. Some customers (especially restaurant service) are seeing a 2/3rds drop in their business. Other sectors, such as Grocery, are seeing unprecedented demand. Either way, that’s a recipe for chaos.
One of the first cultural victims of chaos is usually the safety / regulatory community. We’re easy to ignore whether the reason is “we’re facing layoffs and bankruptcy” or “orders are up 300% and we don’t have time for this.”
On top of that, in a good-faith effort to reassure the regulated community that they understand the burdens we’re under right now, the EPA drafted a policy saying they would use discretion on compliance during the pandemic.
That EPA policy was interpreted by some (the environmental lobby mostly) as a blanket waiver of all regulations allowing the regulated community to pollute at will. More significantly worrying to me personally was the calls, emails & texts I started getting Friday where people in our refrigeration community were being “told” this temporary EPA policy was being used to avoid compliance with their PSM / RMP obligations.
With that in mind, let’s look at what it actually says, shall we?