Chemical Process Safety (PSM/RMP)

One of EPA’s most often cited issues with a facilities Risk Management Plan (RMP) revolves around “updates to the plan”.  Most, but not all, know that the plan has to be updated every five years; but did you know there were other triggers that require a RMP to be updated more often than every five…...

On June 20, 2009, an ammonia line ruptured during maintenance at a poultry processing plant in Robeson County, N.C., killing one employee and injuring several others. This accident should remind employers of the hazards associated with the use of anhydrous ammonia as a refrigerant at food processing plants. Click Here (.pdf) to see and print…...

Update: Download the Updated PSI Evaluation Tool (v 3.02) CCPS initiated a project in late 2006 to develop a focused set of lagging Process Safety metrics to help industry monitor progress and drive improvement in Process Safety Programs. The project, involving a large number of CCPS member companies and external stakeholders, has recommended a concise set…...

OSHA answered this question in 2006 in the LOI, Requirement for flame-resistant clothing in petrochemical plant covered by PSM. Although, OSHA states in the LOI that they will cite the employer for 1910.132(a), 1910.132(d), 1910.119(f)(1)(iii)(B) and/or 1910.119(j)(2). OSHA makes reference to NFPA 2113, Standard on Selection, Care, Use and Maintenance of Flame-Resistant Garments for Protection…...

As many of you already know, having good operating procedures that are regularly reviewed and updated is a vital part of the management process and helps ensure safety. Recently, an industry group conducted a survey on five major companies. See the Directors Corner for the survey questions and the responses of these surveyed companies…. Membership...

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...