Unloading HAZMATs and PSM/RMP

In the past few decades many things have changed in the world of Hazardous Materials and many of these changes DIRECTLY IMPACT our process safety efforts and our PSM/RMP compliance.  The debate will continue as to where DOT stops and OSHA begins when it comes to compliance coverage regarding loading and unloading Hazardous Materials, but this article is more about process safety and what we can do to improve it.  This article is to help those interested to better understand the components of DOT regulations that will IMPACT our process safety and PSM/RMP compliance efforts; from what content goes into our SOPs to facility siting of the loading/unloading areas.  One important aspect to loading/unloading is the high level of risk and these risks can impact a covered process, even though the material(s) being loaded/unloaded is not a HHC/EHS (as noted in an earlier post).  Here is a breakdown of the DOT Loading and Unloading requirements and a brief analysis of how these requirements can be worked into our current PSM/RMP programs, SOPs, as well as “safety systems” we should include in our PSI, SOPs, MOC, MI, etc.

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