Chemical Process Safety (PSM/RMP)

As I have stated already this week, I am a HAZOP kind of guy.  I have used just about every methodology under the sun over the past 25+ years, and I have come to a personal conclusion that in almost every occasion, a HAZOP would have been the best methodology to utilize for a correct…...

Earlier this week I posted about how a PHA should document its consideration of the engineering controls and administrative controls failing. And I said back in the 2013 posting; this little requirement is intended to make facilities dig past a single layer of protection and maybe even identify a lack of engineering and/or administrative controls…...

With all the recent attention being paid to EPA and it’s Risk Management Plan amendments and many of those amendments being rescinded by the new administration, I thought it would be a good time to remind those in the PSM/RMP world, that OSHA has their own wish list (my phrase – not theirs) and some of…...

In the RMP Amendments rule, EPA added three major provisions to the accident prevention program of Subparts C (for Program 2 processes)and D (for Program 3 processes). These included: A requirement in § 68.60 and § 68.81 for all facilities with Program 2 or 3 processes to conduct a root cause analysis using a recognized…...

EPA monetized both on-site and off-site damages. EPA estimated total average annual on-site damages of $265.8 million. The largest monetized average annual on-site damage was on-site property damage, which resulted in average annual damage of approximately $205.5 million. The next largest impact was on-site fatalities ($49.8 million) and injuries ($10.5 million).  EPA estimated total average…...

Over the years I have facilitated and participated in hundreds of PHAs from toxics to flammables and even some explosives (although not my thing!).  And in doing so, one thing that drives me crazy is the lack of structure in how process deviations are identified and studied/analyzed.  I love the HAZOP methodology and hate the…...

In the EPA Office of Inspector General’s Semiannual Report to Congress: Oct 1, 2017 – March 31, 2018 we see two “recommendations” regarding the manner in which EPA conducts their Risk Management Plan (RMP) audits and how the OIG feels the process could be improved upon.  These are a continuation of improvement from the 2013…...

For some reason, we have seen a spike in questions and request to assess the applicability of PSM/RMP covered process(s), and this is beyond the typical “can use the Meer decision to get our flammable process out of PSM?” questions.  So I thought it would be helpful to publish OSHA’s official interpretation and explanation of…...

This week I have been working with a new member who has become frustrated with all the different directions and “interpretations” regarding OSHA’s and EPA’s Maximum Intended Inventory requirements.  This is my e-mail response – names and titles have been changed to protect the innocent! (LOL) I feel your pain, this one small topic has…...

EPA is proposing changes to a final rule, the Risk Management Program (RMP) Amendments (82 FR 4594, January 13, 2017) to better address potential security risks and reasonable consideration of costs. The proposed changes are intended to promote better emergency planning and public information about accidents and maintain the trend of fewer significant accidents involving…...