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SRM News Blog

IIAR Bulletin Updates and PSM

5/18/2017

 
The PSM Standard requires that employers operate and document that their PSM covered process (e.g., ammonia refrigeration system) operates in accordance with recognized and generally accepted good engineering practices, also known as REGAGEPs (29 CFR 1910.119(d)(3)(ii). 
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​IIAR, a leading advocate for the safe use of ammonia in refrigeration systems, has established a number of “Bulletins” that identify how to operate, calculate relief valve sizes, and inspect and manage ammonia refrigeration systems.  They have been commonly used for many years and establish the minimum requirements for industry compliance.

On May 11, 2016, OSHA issued an Enforcement Policy entitled “RAGAGEP in Process Safety Management Enforcement.”  In this policy, OSHA notes that Consensus documents are often used as REGAGEPs and specifically calls out IIAR Bulletins stating that, “Such consensus documents are widely used as sources of RAGAGEP by those knowledgeable in the industry.” 

Recently, IIAR announced that it will be issuing a new Bulletin - IIAR Standard 6: Standard for Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration Systems.  This Bulletin was issued on March 30, 2017 for public review and will be open for comment until May 15th, 2017.  “This proposed standard specifies minimum criteria for inspection, testing, and maintenance of closed-circuit ammonia mechanical refrigeration systems, including the ammonia side of a cascade refrigeration system.”
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According to some in the industry, this new bulletin is going to requirements for maintaining your ammonia systems.   But, your Mechanical Integrity Program should already take into consideration the equipment manufacturers’ recommendations.  But, be ready to review and potentially update your Mechanical Integrity Program with the standards outlined in Bulletin 106.  The document is 129 pages after all.  We’ll have an update on some specific changes soon.
To view the IIAR Proposed Bulletin 6-201X click here.
To view other IIAR Bulletin Updates click here.
To view the OSHA Policy referencing IIAR Bulletins as REGAGEPs click here.

Lake Harbor Park Beach Cleanup !

5/17/2017

 
Join Schneider Risk Management, LLC (SRM),  Blue Horizons Wellness, the City of Norton Shores, the Norton Shores Police Department and the Mona Shores High School Eco-Warriors on June 10th, 2017 in spending a couple of hours making sure the beach is clean and usable for the summer season!  
The beautiful lakes, beaches and woodlands of our area parks are the reasons we love to live, work and play in the Muskegon area.  

Please help us care for our play areas by picking up trash and keeping our parks safe and looking the best they can!  

Donuts, coffee, hot chocolate and conversation will be available. 
Meet at the Pavilion near the parking lot.
 
Sign Up and get more info HERE. 
(http:/www.greatlakesadopt.org/)
**Look for Lake Harbor Park on the left side of the webpage.
 
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The PHIT Act Supports Wellness Activities

5/2/2017

 
​According to PHITAmerica.org, the PHIT Act, which stands for Personal Health Investment Today, is proposed federal legislation that would allow Americans to use pre-tax accounts like Health Savings Accounts (HSA) and Flexible Savings Accounts (FSA) to pay for qualified fitness expenses including memberships, classes and personal training appointments.
 
The PHIT Act will provide an incentive for you and your children to get fit which will help prevent healthcare costs related to preventable chronic diseases.  PHIT would allow you to put up to $2,000 a year into an account and help you save on yearly expenses related to physical activity!
PHITAmerica.org states, “the PHIT Act will put prevention in our healthcare system.  What we have today is basically "sick care".  PHIT will help promote "wellness care" or true healthcare.” 

If you would like to find out more about the PHIT Act and how its benefits, visit this website.

MDEQ Hazardous Waste Rule Changes

5/1/2017

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In case you missed it, the MDEQ has recently adopted a number of federal changes to the Part 111 Hazardous Waste rules, including Solvent wipes.  On April 5, 2017, changes to Michigan’s hazardous waste rules became effective.  ​
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The DEQ indicates that the rule changes were needed to maintain Michigan’s federal authorization to administer the state's hazardous waste program, improve the overall clarity and quality of the rules and reduce the regulatory burdens on the regulated community by providing flexible requirements.  The rule changes did not add new substantial regulatory requirements for managing hazardous waste, but instead provided new conditional exclusions and flexibilities for managing hazardous waste. 
 
Some rule changes were made to the following topics: 
 
Federal Revisions
  • Solvent‑contaminated wipes management
  • Definition of solid waste
  • Carbon dioxide streams in geologic sequestration activities 
  • Establishing a framework for electronic manifesting (E-Manifest)
  • Export of cathode ray tubes
  • Revication of the comparable fuels and gasification rules
  • Disposal of coal combustion residuals from electric utilities
Michigan Revisions:
  • Hazardous waste identification and listing
  • Updates to information associated with items adopted by reference in the rules
  • Typographical corrections
 
The DEQ recently prepared a compliance guide for the Solvent contaminated wipes.  The guide and information about all the changes can be found here.
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A story brought to you by Schneider Risk Management, LLC; your local resource for safety and environmental compliance services.
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  • SRM's Commitment to You
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