Chemical Process Safety (PSM/RMP)

UPDATE from my OSHA contacts:  The NEP was written so that OSHA offices would not single out NH3 refrigeration and CL2 water treatment processes.  OSHA feared that since these processes were so plentiful that they would target these types of processes and not inspect other types of processes, so in reality they were spelled out…...

This table shows the number of RMP facilities — facilities that could potentially have toxic or flammable chemical accidents with off-site consequences. Accident information is summed up from the most recent 5-year accident history for each reported facility. State # of RMP facilities # of accidents # of deaths # of injuries # evacuated Property…...

Yes, EPA has a General Duty Clause for RMP, much like OSHA’s General Duty Clause.  However, EPA’s is much more detail.  This month I came across a facility that used to be a RMP/PSM covered facility, but after much work they lowered their quantities below the RMP/PSM Thresholds.  Once this was done, they literally threw…...

I have had tons of questions and comments on last week’s article regarding EPA’s General Duty Clause as it relates to RMP Listed chemicals (e.g. Extremely Hazardous Substances) and the requirements for employers, EVEN if they were below the RMP Threshold.  As EPA states in one of their Fact Sheets on the GDC…It is important…...

Top 10 RMP Chemicals by On-Site Quantities This table shows amounts of each chemical within processes that have worst-case accidents that could potentially reach off-site. Facilities that are no longer registered with RMP are not included. Chemical Name Chemical Type # of facilities Pounds in processes Ammonia (anhydrous) Toxic 7,672 182,886,947,607 Flammable Mixture Flammable 669…...

Is there a method to OSHA’s madness in regards to the PSM required operating procedures?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

Bryan, Here are some observations related to Bayer PHA effectiveness, as mentioned in the CSB report. The Chem Safety Board Incident Investigation Report for the Bayer incident was very critical regarding the quality / effectiveness of the PHA study. Please take a look over the attached extract from the report and keep these items in…...

You know, sometimes we need to have our efforts validated.  I put myself out there on a daily basis to try my best to educate those who are willing to listen to my ideas and rationale.  I take a lot of hits and it gets to me every once in a while.  But with over…...

Although both EPA and OSHA use similar definitions to define who is an “incidental contractor” and those contractors who need to be evaluated to work in, on, or adjacent to a “covered process”, there is still much confusion on the intent of the “contractor element” and which type of contractors should be included and the…...

Some interesting data on Anhydrous Ammonia releases in NY state from 1993-1998…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

I have been asked to explain the difference between actions an operator may take during a process leak and the actions that the same operator may take as an “emergency responder” to the leak…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...