Risk Management Plan

June 23, 2021

A portion of the SCS Tracer Environmental team at a RETA conference. Close teamwork and quality are essential.

 

The purpose of SCS’s internal Quality Management System (QMS) is to provide our clients quality solutions ethically. With that goal in mind, SCS Tracer Environmental (a specialty practice at SCS Engineers) has developed numerous internal systems to provide quality consulting services.

For example:

  • We use an internal project checklist to ensure we consistently deliver quality reports and safety programs.
  • Our cross-training allows our team to provide a wide range of OSHA’s Process Safety Management and EPA’s Risk Management Plan-related services.

To help our clients stay in compliance, Tracer developed another quality-related system to track recurring compliance due dates for our nearly 400 clients. Our due date tracking system allows us to generate reminders for them before their actual need.

Tracer’s system of quality programs has evolved; however, the key component of providing quality solutions remains unchanged – teamwork. Without teamwork, no quality system will create success. This collaborative effort within Tracer and other practices at SCS Engineers helps us achieve our common goal of delivering quality solutions.

Sometimes that means we need to step up and help a colleague on a project with a quick turnaround time. Or, if the unexpected happens, a new project manager may need to jump in – sometimes mid-project. We take the initiative to respond to all client emails if we know the client manager is unavailable. We form internal committees to revise procedures, checklists, and templates, always intending to improve efficiency and increase quality.

Merriam-Webster defines teamwork as “Work done by several associates with each doing a part but all subordinating personal prominence to the efficiency of the whole.” With mutual trust and respect, and the free exchange of knowledge in a collaborative environment, we continue to deliver quality through teamwork.

 

We thank our SCS Quality Management Gurus, who are always helping us find better ways to deliver excellence!

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

June 1, 2021

epa rmp

 

May 27, 2021, from two separate U.S. Environmental Protection Agency (EPA) announcements:

EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule

Congress provided authority to states and Tribes under CWA Section 401 to protect the quality of their waters from adverse impacts resulting from federally licensed or permitted projects. Under Section 401, a federal agency may not issue a license or permit to conduct any activity that may result in any discharge into navigable waters unless the affected state or Tribe certifies that the discharge is in compliance with the Clean Water Act and state law, or waives certification.

EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule to restore the balance of state, Tribal, and federal authorities while retaining elements that support efficient and effective implementation of Section 401. While EPA engages with stakeholders and develops a revised rule, the 2020 rule will remain in place. The agency will continue listening to states and Tribes about their concerns with implementing the 2020 rule to evaluate potential administrative approaches to help address these near-term challenges.

The agency’s process of reconsidering and revising the 2020 CWA Section 401 Certification Rule will provide an opportunity for public and stakeholder input to inform the development of a proposed regulation, and will include sustained dialogue with state and Tribal co-regulator partners and local governments around these issues. EPA will begin a stakeholder engagement process in June to hear perspectives on this topic and how to move forward. More information will be available at: www.epa.gov/cwa-401.

 

EPA, Region 7, public listening sessions on the RMP Rule

Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are in the Risk Management Plan (RMP) rule, which requires facilities using extremely hazardous substances to develop a Risk Management Plan that:

  • identifies the potential effects of a chemical accident,
  • identifies steps the facility is taking to prevent an accident, and
  • spells out emergency response procedures should an accident occur.

These plans provide information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community.

The Region 7 EPA announced two upcoming virtual public listening sessions on the Agency’s Risk Management Plan (RMP) rule. The RMP rule has been identified as an action for review under Executive Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis.

The listening sessions will give people the opportunity to present information, and provide comments or views pertaining to revisions made to the RMP rule since 2017. The Occupational Safety and Health Administration (OSHA) will also participate in the listening sessions and receive comments on their Process Safety Management (PSM) standard, which contains similar requirements to the RMP rule.

Virtual public listening sessions will be held on:

  • June 16, 2021, from 12:00 p.m. to 4:00 p.m. ET.
  • July 8, 2021, from 4:00 p.m. to 8:00 p.m. ET.

For more information on the public listening sessions:

https://www.epa.gov/rmp/forms/virtual-public-listening-sessions-risk-management-program-rule.

Submit written comments via the docket at: http://www.regulations.gov,  Docket ID: EPA-HQ-OLEM-2021-0312 until July 15, 2021.

EPA Region 7 serves Iowa, Kansas, Missouri, Nebraska, and Nine Tribal Nations.

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 11:17 am

January 28, 2019

Reflection, as a means of self-evaluation of the robustness of your refrigeration management system, is critical to the continuing success of your program.

Proper planning is another vital element of your program. Together, they will help ensure the continuing safety of you, your employees, and the public.

Bill Lape, a Certified Industrial Refrigeration Operator and a member of the National
Board of Directors of RETA is a Project Director for SCS Engineers.  In his most recent article,  Bill provides advice to use January and early February as a time of reflection and a planning period. We need to look closely at our ammonia refrigeration management programs, be they Process Safety Management (PSM) / Risk Management Plan (RMP) or Ammonia Refrigeration Management (ARM) for facilities with less than 10,000 pounds of
ammonia in their process.

Click to read the article, and thank you for interest in maintaining safety standards.

Process Safety Management,  Risk Managment Plans, Ammonia Refrigeration Management information.

 

 

 

 

 

Posted by Diane Samuels at 6:00 am