Ever heard anyone say, “PSM and RMP are identical except for the off-site consequence requirements”? There are a lot of similarities between the two chemical safety regulations, but the two are very much different in more ways than just the “off-site consequence requirements.” Most similarities are between RMP “Program 3 Prevention Program” and OSHA’s PSM…...
Difference between OSHA’s PSM and EPA’s RMP requirements Read More »
Toxic Chemicals Regulated under RMP that are also Regulated under PSM [Alphabetical Order – 78 Substances] Chemical Name CAS No. RMP Threshold Quantity (lbs.) PSM Threshold Quantity (lbs.) Acrolein [2-Propenal] 107-02-8 5,000 150 Acrylonitrile [2-Propenenitrile] 107-13-1 20,000 Not Regulated Acrylyl chloride [2-Propenoyl chloride] 814-68-6 5,000 250 Allyl alcohol [2-Propen-1-ol] 107-18-6 15,000 Not Regulated Allylamine [2-Propen-1-amine]…...
Comparison of RMP and PSM Chemicals and Thresholds Read More »
The Massachusetts Department of Fire Services (DFS) has enacted the Hazardous Materials Processing regulation (527 CMR 33). The code was developed to help prevent the occurrence of incidents like the explosion in Leominster in 2005, the fire and explosion in Danvers in 2006 (see the CSB investigation), and the fire and explosion in Middleton in…...
State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33) Read More »
Most ammonia refrigeration personnel know their refrigerant is flammable, but most would also tell us that they do not have any “Hazardous Locations” (e.g. Class 1, Div 1 or 2 locations) associated with their refrigeration process. Most of these workers will explain their engine room/compressor room ventilation system is designed, installed, and maintained to ensure…...
Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12) Read More »
Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement? Absolutely not! Somewhere this little fib began and it has spread like wildfire. If you have a release of your HHC/EHS during unloading or loading, rest assured OSHA and/or EPA can investigate and inspection, and here’s why…… Membership Required You must be a...
Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement? Read More »
This is not meant to be a trick question, but many think it is. A close examination of the specific wording in the PHA element of the RMP rule will quickly identify DIFFERENT wording than what is in OSHA’s PSM std (just another example of how these standards are NOT identical!)…. Membership Required You must...
Can a PHA done for OSHA’s PSM be used for EPA’s RMP Compliance? Read More »
NOTE: Members should also read Process Safety and our pipe flanges (type of bolts, threads showing, etc.) Some may claim this to be a trick question. I assure you it is not meant to be, but as I will point out in this article, having too much bolt extending beyond its nut can be an issue,…...
How many threads of a bolt must be showing outside a nut to meet RAGAGEP? Read More »
Here are some of my favorite Hotwork Safety Talk and Training resources. They may be helpful at your facility…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Hotwork – Learning from Losses Read More »
There is some language in the EPA’s Risk Management Plan program requirements that tends to cause some confusion… The owner or operator of a stationary source shall revise and update the RMP submitted under §68.150 as follows: (5) Within six months of a change that requires a revised PHA or hazard review So when are we…...
Change(s) that REQUIRE a PHA revalidation AND RMP Update Read More »
NOTE: this data is a bit dated, but for those interested…An overview of some basic statistics derived from the RMP*Info database is informative and will help place more detailed assessments in context. As of this writing, the RMP*Info database contains information on a total of 14828 facilities containing 20210 chemical processes. Of these processes, 17529…...
Interesting RMP Statistics – Where does your process rank? Read More »
Point -Counter Point PSM Discussion. Below is my position and counter to “my opinion” is that of a friend who specializes in PSM for the refrigeration industry. You can read his position at his website taocomplaince.com Scenario: You have a freezer with racking. The racking inside this freezer needs to be replaced. You hire a…...
PSM Scenario Challenge – Response Read More »
“Hot work” means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations. Click “Read More” below to view and download the ppt…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
