Recent Blog Posts

Management of Change & Pre-Startup Safety Review (Part 2)

September 4th, 2018

In Part 1 of this series, we examined the purpose of Management of Change and Pre-Startup Safety Review (MOC/PSSR) and how to determine when it is required. We will now review the specific requirements of MOC/PSSR. RMP/PSM/CalARP regulations are very similar on the prescriptive requirements for both MOC and PSSR. For simplicity, we will look […]

Management of Change & Pre-Startup Safety Review (Part 1)

August 21st, 2018

When I first got into Process Safety Management, Peter Thomas advised me, “If you want to be an expert in anything, be an expert in Management of Change and Pre-Startup Safety Review.” He then added that if you understand MOC/PSSR requirements, you will understand how every other element is affected by a process change. Now […]

Contractor Training

February 7th, 2017

Recently I was involved in a CalOSHA PSM inspection where CalOSHA requested that the facility provide “contractor training records related to any and all work done on the ammonia process done by contractors”.  The response from the facility was: “Who is responsible to train contract employees who perform work at my facility?”  This is a great […]

Ammonia Week in Review | January 27, 2017

January 27th, 2017

Ammonia headlines cover a wide range of issues in this week’s edition of the Ammonia Week in Review…..   UK Sausage Maker Switches to Ammonia – UK meat wholesaler James T. Blakeman & Co., the company behind popular British brand Supreme Sausages, has chosen to retrofit its system based on R404A – which is being gradually phased down […]

Strategies for Maintaining PSM Compliance (Part 3)

January 10th, 2017

Let’s be honest… you work a lot. Sometimes too much. You do it because you take your job seriously and want it done right. The reality however, is you are stretched thin and on the verge of burnout. The big question then becomes, “How can you accomplish all your regular responsibilities AND maintain a sufficiently […]