Chemical Process Safety (PSM/RMP)

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

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]

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

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

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…

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!).

Here are some of my favorite Hotwork Safety Talk and Training resources.  They may be helpful at your facility.

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

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