Bryan Haywood

The first (1st) public review of draft standard IIAR 4-201x, Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems is now open. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.  IIAR 4 specifies criteria for the installation of closed-circuit ammonia refrigeration systems. It presupposes that […]

How many process safety management systems for ammonia refrigeration have you seen that included “temporary operations”? There seems to be an industry-wide mind set that there are no “temporary operations” in ammonia refrigeration. Heck, even the largest ammonia refrigeration trade group states there are is no such thing as “temporary operations” in the ammonia refrigeration

RMPs must be updated at least once every five (5) years.  You must fully update your RMP for resubmission sooner than the five-year anniversary date, if any of the changes specified below occur [as specified in 40 CFR 68.190(b)]. If a change alters the Program Level that applies to any covered process, the RMP must

We are often questioned about our audit methology and techniques.  Clients ask… “How did you know to ask me about that?” or “Why in the world do you want to see that for in a PSM/RMP audit?”  Well, here is one way I learned what gets asked for; attached is an official EPA RMP Inspection