Bryan Haywood

Is IFC 2021 Performance-Based Design Alternative better than OSHA’s PSM and EPA’s RMP?

For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67).  This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been

EPA RMP Citations @ (NH3 & Cl2 & Compliance Plan)

Respondent is the owner and/or operator of a facility that uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. During the inspection, the EPA representative observed alleged violations of section 112(r) of

EPA’s 2022 RMP Activity

In FY 2022, the agency continued its efforts to reduce risks of accidental releases at industrial and chemical facilities, such as: Concluded three (3) judicial actions, 145 administrative penalty actions, and 18 administrative compliance orders In FY 2022, EPA renewed its presence in the field and increased its on-site inspections by more than 150% compared to

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