On the most basic level, can a PSM/RMP program function and comply with all regulatory requirements and NOT have a calibrated direct-reading instrument?
This is not meant to be a trick question, but rather looking to “ground me” in my expectations. Having grown up in the PSM/RMP era in petrochem for 20 years, having a calibrated direct-reading instrument available was like having my hardhat and safety glasses available. I do not think a day went by where I did not personally rely on a portable gas detector. In fact, several of my plants we were REQUIRED to wear a detector at all times while signed into the unit. But the $64M question is…