Chemical Process Safety (PSM/RMP)

OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F…...

We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is…...

Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM…. Membership Required You must be a member to access this content.View Membership...

OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel…...

“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or…...

A lot of PSM/RMP covered processes utilize ventialtion as an engineering control within the process.  And if this is the case, then OSHA and EPA require the facility to have supporting documentation to show that the ventilation will do what it it intended to do…. Membership Required You must be a member to access this...

No hunman and no organization is perfect!  Although we should strive for perfection in all aspects of business (Production, Quality, Cost Control, and EHS), we often mis-step or possible loose our way altogether.  But how bad do things have to get before it is a REAL PROBLEM?… Membership Required You must be a member to...

I continue to see facilities struggle with the emergency shutdown SOP requirements and how it is all suppose to flow and fit into the daily operations.  In this post I will try and lay out a flow to help make sense of these PSM/RMP requirements.  I am hopeful you can learn from my mistakes, as…...

Does the title make you scratch your head? I usually get some strange looks when working with a client who is trying to understand what the PSM compliance cycle looks like. To start with, let’s look at what OSHA/EPA requires in our operating procedures: 1910.119(f)(1)(ii) Operating limits 1910.119(f)(1)(ii)(A) Consequences of deviation 1910.119(f)(1)(ii)(B) Steps required to…...

Many chemical processes that are covered under OSHA’s PSM and EPA RMP rules utilize one of the most popular forms of passive mitigation ever known…Diking.  However, on the other hand, many of the facilities have not included their dikes in their Process Safety Information (PSI) or their Mechanical Integrity Programs (MIP)…. Membership Required You must...