Let us help you make sense of PSM / RMP!
We’ll be having an open-enrollment PSM class in Burleson, Texas July 8th-11th 2025.
You can get more information on the class with this link.
We hope to see you there!
Category: PSM Templates (Page 1 of 3)
(Apologies for the late post – a scheduled post did not happen. These changes took place 3/8/24)
The Various ITPMR’s, the Walkthrough Form & SOP, etc. were all re-reviewed line-by-line to ensure closer compliance with IIAR 6. Many, many changes were made based on this review. A detailed changelog follows:
IIAR 2 – 2021 Standard for Design of Safe Closed-Circuit Ammonia Refrigeration Systems has been released by the IIAR and is now available for purchase on their website.
The updated standard has several new requirements which resulted in some changes in the PSM/RMP program templates. Here are some of the highlights:
- The definitions file was updated with new IIAR 2 definitions. Added in-document headings to skip around the document easily.
- The PHA Checklist Template was updated to the new IIAR 2:
- Added a note that “Provisions for plugs or caps required under IIAR 2 5.9.3.3” on all oil draining plug/cap questions.
- Added a note that “IIAR 2-2021 5.12.2 requires a check valve during charging” in relevant Charging SOP section.
- Added a question on Provisions for Pumpout per IIAR 2-2021 5.12.6 on PV1 subsection and all Equipment Subsections.
- Added/Modified questions on RC1 section about low ambient temperature, and VFD resonance.
- Added a question on EV2 (Liquid Heat Exchanger) equipment subsection regarding secondary coolant side pressure ratings.
- Added a question on MR.C Checklist for Classified Space signage.
- Added a question on PV1 (Piping & Valves) on new MOPD & MSSPD requirements for valves leading to atmosphere.
- Added a question on PV1 (Piping & Valves) on requirements for unique identification for Emergency Shutoff valves.
- Modified existing .PSV equipment sub-subsections to include IIAR 2 2021 15.2.6 requirement that liquid relieving reliefs relieve back into the system.
- Added a note that IIAR 2 2021 13.2.3.1.1 limits carbon steel tubing and carbon steel compression fittings to valve sensing pilots, compressors, compressor packages, and packaged systems to all small-bore piping / tubing questions.
- Updated MR.C section for new requirements regarding NH3 detection.
- Updated various checklists (VENT, DET, PSV, DT) to match current IIAR 2-2021 text.
- Added a new equipment subsection NMR.C for IIAR 2 Equipment located outside of Machinery rooms.
- Added a new equipment subsection PKG.C for IIAR 2 Packaged Systems and Equipment.
- Added a new equipment subsection IAC.C for IIAR 2 Instrumentation Controls.
- Updated “Contractor Door Sign” to meet new IIAR 2 – 2021 [5.14.1.1] information standards and some ASHRAE 15 – 2019 [11.2.1] standards.
Comments about the changes and the required steps to implement the document changes are present in the “Change Log and Reference” document at 08/02/21.
…Read on further in this post if you want to know about the changes in the new IIAR 2…
According to 1910.119(e) and 40CFR68.67(a) the purpose of a PHA is to “…identify, evaluate, and control the hazards involved in the process.” Since the mid-90’s the refrigeration industry has done this mainly through the IIAR’s “What-If” methodology as suggested in their Compliance Guidelines materials.
There have been many revisions of this material over the years, but they all have the same thing in common as you use them: You can see how each question / item:
- Poses a failure scenario (sort of a lesson someone else has already learned)
- Prods you to solve the issue through an existing RAGAGEP
For example, a question might ask something like “What if plugs, caps, or blind flanges are missing on purge or drain valves?” This should prod you to recall that both IIAR 2 and IIAR 4 require that these things be plugged, capped, etc. This should also prod you to ask how you are addressing this requirement in your Process Safety Program.
The issue we always came across is that you must KNOW or MEMORIZE what the RAGAGEP says in a very complete way, or you miss the connection between the “What If” scenario and the RAGAGEP. This is nearly impossible because it seems like RAGAGEP is multiplying at an alarming rate. Furthermore, this (at least two day) process often feels like a futile effort at figuring out what the “What-If” scenario questions are really getting at.
To improve this years ago, I started adding two things to the IIAR standard questions:
- References to the IIAR standards where appropriate. (For example, in our plug question, reference IIAR 2-2021 13.3.2.6 & IIAR 4-2020 10.4.5.4)
- Explicit checklists that allow you to compare your system to appropriate RAGAGEP outside of the “What If” scenarios.
It’s very easy to lose sight of evolving RAGAGEP over time. These checklists allow you to perform a forensic examination of your system compared to current RAGAGEP. In addition to the issue of improving RAGAGEP compliance, we also face other challenges.
- It is common to show up to perform a PHA and find the client lacks critical Process Safety Information and PSM elements & procedures making a compliant PHA extremely difficult or impossible.
- Incident Investigations are often in a state of disarray or incomplete making their inclusion in the PHA difficult at best, and almost meaningless at worst.
- IIAR 9 now requires an evaluation against its minimum requirements for all NH3 refrigeration systems at least every five years.
- In some regions the EPA has an almost absurd number of questions they “like” to see in your Facility Siting sections.
- The Emergency Action Plan is a critical safeguard in your program, and it is usually missing some basic items that aren’t apparent until you try and use it in an emergency.
- Finally, the IIAR has standards on Installation, Commissioning, and Decommissioning that are often overlooked.
This again leads us back to checklists. I created them for basic PSI & PSM items, Incident Investigations, IIAR 9, Facility Siting, EAP, IIAR 4, IIAR 6, and IIAR 8. Here’s what that looks like:
As you can see, that’s fairly comprehensive, but it’s also a lot more work! To adjust to all this, we usually perform PHA’s in a two-step process.
Step 1: Weeks in advance, we give the client the relevant checklists and have them fill them out to the best of their ability.
Step 2*: Once we’re on-site, we go over the checklists they’ve worked on to answer any questions, address discrepancies, etc. THEN we move on to the “What If” scenarios.
* Of course, if the client wants, we can always book another two or three days of our time helping them on-site with Step 1.
The result of this longer, more comprehensive process is:
- A nearly point-by-point check of the facility (and their Process Safety program) against common RAGAGEP from a HAZARD perspective rather than a compliance one.
- A much better understanding of the “What If” scenario questions when we get to them after the checklists.
- Cleaner, more systemic recommendations that point to specific hazards and the RAGAGEP that most effectively addresses them.
- At the end of the PHA process, facility team members have a much clearer understanding of where the requirements and recommendations are coming from.
You can learn more about our PHA offerings here. Email or call us today to have RC&E assist you with all your PSM/RM Program needs! info@RCE-Chill.com (888) 357-COOL (2665)
Merry Christmas to our Ammonia Refrigeration Process Safety community!
Well, this year has been interesting, eh? The hits keep coming it seems, and it was no different to those of us in the Process Safety field. Behind the scenes, we’ve been working on a fairly major set of improvements to the PSM system. Originally scheduled for August, we’ve finally managed to push it across the finish line just in time for the Holidays!
Significant improvements were made to the core of the system (The SOPs and ITPMRs) through an unprecedented amount of end-user feedback. Remember, this system relies on the feedback of operators, technicians, service personnel, and Process Safety professionals to improve.
All updated documents have the 122520 date-code, but here’s a run-down:
- Minor updates to definitions file
- All element written plans:
- Where it was appropriate, did a little harmonization with the newest IIAR Process Safety Management & Risk Management Program templates. (There isn’t really anything they cover we don’t, but there are some places we harmonized the phrasing where we cover the same ground)
- Ensured all element Written Plans refer to the ROSOP QA – Document Quality Control section in the Document Management
- Minor editing / formatting improvements
- Minor change to Operator Training element to ensure that Initial Training on Incident Investigation includes a review of recent and routinely recurring incidents.
- Improvements to the II element written plan’s “Incident Investigation Process Flowchart”
- SOPs
- Minor changes to the Implementation Policy: Review and Annual Certification to harmonize with the IIAR guidance
- Annual SOP Certification letter improved to correlate with the SOP element Written Plan more closely
- The SOP element Written Plan Implementation Policy: SOP Authoring / Generation section now provides “Best Practices” standard language for warnings, step comments, step instructions, etc.
- ALL SOP Templates now:
- Use the “Best Practices” language.
- Include better language tying them to the ITPMRs
- Reference ROSOP-PPE in the Safety considerations section
- Additional Equipment Considerations added to harmonize with the IIAR guidance
- ROSOP PPE slightly improved with reference to LEO
- ROSOP LOTO improved with improved language from end-users
- Minor updates to ROSOP QA – Document Quality Control section.
- ROSOP LEO streamlined and simplified with a good amount of end-user feedback
- New ROSOP ITPM based on significant end-user operator input and feedback (See MI section below)
- MI / ITPMRs
- All ITPMRs now provided as PDF forms as well as Word documents
- All ITPMRs have improved references including to the new ROSOP ITPM
- All ITPMRs now have a space to record task hours
- All frequency ITPMRs are now in a single document. For example, previously we would have a 30-day, 90-day, and 365-day ITPMR for condensers. Now we have a single ITPMR for condensers with all the items and you simply use the applicable sections. This allowed each step in the ITPMRs to have its own unique step code. This is important because….
- A new SOP was created called ROSOP ITPM which includes additional information for less-skilled operators and technicians. This new ROSOP also is used as a repository of best-practices and collected knowledge from field operators. Relevant guidance from applicable IIAR standards was also included directly in the SOP where we thought it useful to those performing the MI work. A group of contractor service technicians and end-user operators contributed to the creation of this SOP and We FULLY expect this SOP to grow and improve as we get even more field use and operator feedback.
To implement:
- Written Plans: Follow the Implementation Policy: Managing Procedure / Document Changes. These should be straight-forward.
- Definitions file: Replace with the new one
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- For the new PPE and LOTO templates, either adopt them as-is or incorporate their changes to your existing PPE & LEO SOPs
- For all your equipment SOPs, consider updating them to the new language during your next scheduled revision / team review.
- For the NEW ROSOP-ITPM and PSSRs see the MI section below
- MI: Replace the existing ITPMRs with the new ones, providing training that when the CMMS (or other scheduling system) calls for a frequency based ITPMR, just use the equipment specific ITPMR and fill it out to the appropriate frequency.
- Provide training on the new ROSOP ITPM. Please collect feedback for improvements so we can all improve its performance.
IIAR 4-2020 Installation of Closed-Circuit Ammonia Refrigeration Systems and IIAR 8-2020 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems have been released by the IIAR and are now available for purchase on their website. IIAR 8 didn’t change much, but this was a very significant change to the existing IIAR 4 standard.
In SHORT, here’s what you need to know as an end-user:
- For current/future projects that involve the installation, startup, and commissioning of new equipment, use the “IIAR 4 APP-B Checklist Tracking Log Template” to manage adherence to IIAR 4 before, during, and after the installation. Once this tracking log has been completed, you can document the final status in the PHA .ISC.APPB section of the related project PHA. (The tracking log is in \PHA\PHA Study Template\Optional Resources\)
- Ensure future PHA’s (including project PHA’s) comply with the requirements of IIAR 4 by using the existing equipment specific .ISC section and the new .ISC.C checklist section.
The long version follows…
Continue reading
Powered Industrial Trucks (PIT) in Machine Rooms are a known struck-by hazard. What most people don’t realize is how serious the results of a PIT impact in a Machinery Room can be.
For example, a forklift / scissor lift impact that shears a 3″ TSS (ThermoSyphon Supply) or HPL (High Pressure Liquid) operating at a typical head pressure of 160PSIG results in a release rate of over 18,500 pounds per minute.
Many facilities attempt to establish a ban on PIT in their machinery rooms, but while the needs for PIT in machine rooms are very limited, there are situations where they are necessary. An outright ban won’t likely survive prolonged contact with reality.
To address this issue in a PHA, we usually recommend a Written Machine Room PIT policy as an administrative control. For years we’ve discussed the content of that policy informally with people. Recently a PSM coordinator shared her written policy & permit with us and after some alterations and formatting, we’re adding it to the SOP Templates section.
Front of the Permit:
Back of the Permit with additional explanations:
As always, you can find this on the Google Shared template drive.
The story so far…
Dec 2016: Outgoing Obama EPA releases changes to the RMP rule on the way out the door.
Apr 2017: Incoming Trump EPA puts the RMP rule changes on hold.
Jun 2017: Trump EPA further delays the RMP rule changes.
May 2018: Trump EPA proposes new RMP rule changes, reversing Obama changes.
Aug 2018: DC District Court reverses Trump Rule and re-instates Obama rule essentially making it the existing rule with compliance dates in the past. Trump EPA is basically told that it can change the rules, but it needs to follow different procedures to do that. Trump admin appeals and the rule changes are put on hold.
Sep 2018: Trump admin loses appeals. Obama RMP rule changes are officially LIVE. Trump EPA announces that they will follow the different procedures and change the rule the right way. (Not-so-secretly, the entire EPA is told NOT to enforce the new rule, but out of an abundance of caution, most RMP adherents implement the changes anyway. After all, it IS the law.)
Dec 2019: Trump EPA officially posts the new rule and places it in the CFR making it LIVE on 12/19/19. (See links at the end of the post)
So, where do we stand now?
Ok, we’ve got a new RMP rule. It appears to have gone through the correct rulemaking process. It’s been published in the Federal Register making it the law of the land.
So, what do we do now?
Well, let’s be honest; the Trump administration IS GOING TO GET SUED over this. What happens then? Who knows!? If you follow the courts in modern America, you know there is very little that can be accurately forecasted.
What we do know is that we have a new rule. The new rule appears to have been done correctly with sound documentation as to the reasoning for the changes. In my opinion, the new rule will LIKELY hold up in court. Even if it doesn’t, it is highly unlikely the EPA could get away with fining / citing people for not following a court-reinstated rule under such a cloud of confusion.
In any case, the new rule is easier to follow and makes more sense than the Obama EPA rule changes did. It reverts the majority of the RMP rule to match the PSM rule where they SHARE jurisdiction. The only substantive changes are to the EPA-specific areas where the EPA alone holds jurisdiction.
Ok, so how do I comply with this new rule?
If you do use our template system, I’ve got some good news for you! This is where using a set of open-sourced, professionally curated templates really shines. ALMOST ALL THE WORK has been done FOR YOU!
- To improve your understanding of the new rule, read how we changed the program to meet the new requirements. This will help you to train your colleagues on them.
- Replace existing copies of the affected Written Plans / Forms, taking a moment to look at the changes between the older versions and the new ones.
- Implement new EAP-C form.
- Modify the MI-EL1 EAP/ERP line to reflect the new text.
- Train all Responsible Persons and affected management on the new policies.
Note: Estimated time for the above is about 2-4 hours depend on how well you know your PSM/RMP program.
On the other hand, If you don’t use our template system, you’re going to have to re-create the work I’ve already done:
- Skip to the end of this article to get the links to the new information.
- Read the 83-page Federal Register notice and make a series of notes about the new requirements. You can probably skip the 109 footnotes for now.
- Compare those new requirements to the version of the RMP rule your program is CURRENLY written to comply with; whether that’s the pre-Obama, Obama, or Trump proposed version.
- Starting at the beginning of your program, read through each of your Element Written Plans and see what changes have to be made. Refer to your notes from the first step. (You may wish to read how we changed our program to meet the new requirements)
- Update / alter your program to meet these new requirements.
- Train on these new changes
Note: Estimated time for the above is about 40-80 hours depend on how well you know your PSM/RMP program and the EPA RMP rule.
Template Program changes in detail
Please note, where not specifically shown below all affected Element Written Plans had their CFR section updated to the current 12/19/19 CFR.
| Element | What Changed | Changes to Program Templates |
| 01 – RMP |
|
|
| 02 – EP | N/A | None |
| 03 – PSI |
|
|
| 04 – PHA |
|
|
| 05 – SOP | N/A | None |
| 06 – OT |
|
|
| 07 – CQ | N/A | None |
| 08 – MI | No changes to RMP requirements |
|
| 09 – HW | N/A | None |
| 10 – MOC / PSSR | No changes to RMP requirements |
|
| 11 – II |
|
|
| 12 – EPR |
|
|
| 13 – CA |
|
|
| 14 – TS |
|
|
Item-by-Item changes:
- Reference\EPA Reference\ has been updated with a PDF of the Register Notice.
- Reference\CFR – Text of Federal Rules\ has been updated with a complete and formatted CFR reflecting the new changes.
- The various element affected template directories have been updated with Element Written Plans that incorporate the new CFR text AND modified policies to comply with the rule changes
- 01 – EPA RMP
- Element Written Plan – REPLACE
- 03 – Process Safety Information
- Element Written Plan – REPLACE
- 04 – Process Hazard Analysis
- Element Written Plan – REPLACE
- PHA Worksheet Template – REPLACE
- 06 – Operator Training
- Element Written Plan – REPLACE
- 08 – Mechanical Integrity
- MI-EL1 Form updated. You may just wish to modify the EAP/ERP line to reflect the new text rather than re-create the form.
- 10 – Management of Change and PSSR
- Element Written Plan – REPLACE
- 11 – Incident Investigation
- Element Written Plan – REPLACE
- 12 – Emergency Planning and Response
- Element Written Plan – REPLACE
- NEW Form EAP-C – Implement
- 13 – Compliance Audits
- Element Written Plan – REPLACE
- Optional Combined PSM RMP Compliance Self-Audit Checklist – REPLACE
- 14 – Trade Secrets
- Element Written Plan – REPLACE
- 01 – EPA RMP
EPA links for new information:
- Updated CFR (aka “law”) from eCFR: link (37 Pages)
- Federal Register Notice including reasoning for changes: link (83 Pages)
The spirit of Christmas may be behind us, but the spirit of Continuous Improvement never leaves us alone. (for better or worse, lol)
After months of minor changes and revisions off-line, the 2020 SOP templates have been released. Please note: These are IMPROVEMENTS, not compliance or safety-critical changes. As such, there is no need to go back and change your existing SOPs. We would, however, suggest you use these new formats as you implement new SOPs. Of course, it’s possible, you may want to take advantage of some of the features of these new SOP templates, and you’re welcome to convert to them if you have the time.
Changes to ALL SOP Templates:
- Moved “Covered Equipment” to “Objective” section which eliminates Document Info section.
- Moved “Related Documents” to “Objective” which eliminates Related Documents section.
- Removed “SOP Objective” from first section as the objective is repetitive and explained clearly in the Written Plan. (It’s the first text box of the SOP so it’s fairly obvious what the function is!)
- Made Safety Warning triangle smaller and made the warning RED. This change (among others) frees up a bit of room for the Safety, Health, Environmental and Equipment Considerations section
- Moved the Operator Requirements concerning authorization to the top of the Safety, Health, Environmental and Equipment Considerations section thus eliminating the Operator Requirements section. Also provided a callout to the operator to check their OT1 to ensure they’re qualified to perform the procedure.
- Modified the Operating Phase flowchart section layout to take up less space.
- Minimized the left-hand column which shows what “Section” you are in to 1” width to take up minimal space. Centered the section text.
- Placed Headings between sections. This required splitting up the various Operating Phase / Procedural sections but makes navigation much easier if being used in WORD or PDF format.
- Added complementary color to enlarged text “body” sections of Operating Phase / Procedural Sections.
- Valve / Component List given a header. Sub-header appropriately colored.
Why did we make those format changes?
- Those changes yield a slightly shorter SOP format (average 1 page loss per SOP)
- These are collections of various suggestions we’ve received over the past year from end-users.
- The resulting SOPs are much more visually appealing, especially on tablets.
- The resulting SOPs are much easier to navigate on tablets, which alot of users are implementing for their technicians.
Additional changes were made to some other SOP templates:
- HPRTSR: Updated the System Charging procedural section based on user feedback.
- HPR: Added a Cylinder Charging procedural section for those users that want that option.
- LEO: Traditional Permit LEO was simplified and now only has “Existing SOP,” “With Drain Valve,” and “Without Drain Valve” sections. The previous 4 possibilities was confusing to some and this one seems to be easier to understand.
Occasionally we come across an issue we’ve customarily addressed, but never documented. Put another way: We realize we have a policy – even if an informal one – on how to deal with certain situations, but we’ve never turned that policy into a formal, written one.
It’s incredibly common to have these informal policies in smaller departments, or when a task is rare. You can usually identify them after-the-fact when you are told “That’s just the way we do things here. Everybody knows that.”
When we find these items in our Covered Processes, we should endeavor to document them. Today I’d like to talk about a big one: What do we do when the existing written procedures don’t match with the conditions or situations we are facing in our work. What written guidance are you providing to your Process Operators and Technicians on how to deal with this situation?
Every functioning Operations / Maintenance department has a policy – even if an informal, undocumented one – on how they deal with this issue.
For years I’ve relied on the text in the SOP Written Plan concerning Temporary Operations:
The ammonia system is not operated in any temporary modes without a written SOP. If a component requires maintenance or replacement, that portion of the system is isolated and removed from service through a written SOP. Other Temporary Operations are handled through the MOC element which will ensure supervisory oversight. Temporary Operation SOPs are often via a written modification of an existing SOP in the form of an addendum.
This worked well, but it was a little bit obscure and (understandably) only thought to apply to SOPs themselves. That needed to change. What we’ve done to our system today, is formalized and documented guidance on how to deal with these non-standard / non-routine situations.
A new policy was placed in the RMP Management System Written Plan…
To ensure integration of this policy, the following text was added to the Operating Procedures (Implementation Policy: Using an SOP – Performing a Procedure, and Implementation Policy: Operating Phases, Temporary Operations) and Mechanical Integrity (Implementation Policy: Mechanical Integrity Procedures or MIPs) element Written Plans: “The Implementation Policy: Non-Standard Work. Addressing Conditions / Situations outside of existing Procedures found in the RMP Written Plan should be used when site/equipment/system Conditions or Situations are found to be different than those anticipated in the exiting written procedures.”
Are you handling non-standard / non-routine work well in your Process Safety program? If you are, and have a better idea, we’re always open to improvements. If you aren’t handling it well, perhaps you can implement the example above?
For Inside-Baseball type people: This chart was inspired by the API RECOMMENDED PRACTICE 2201 Safe Hot Tapping Practices in the Petroleum and Petrochemical Industries, Chapter 4, Section 4.3.1, Figure 3—Example Decision Process for Authorizing Hot Tapping. Other than genericizing that flowchart to cover all types of work, I also made two large changes:
- Routed the post “change conditions” step back to the start so we re-evaluate the existing procedure considering changed conditions/situations rather than short-circuiting back to the Management step.
- Rewrote the flow/wording so that Condition Changes are preferred over mere procedural changes. The thinking was that we should prefer more engineering-type changes over administrative ones, where possible.
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