Chemical Process Safety (PSM/RMP)

EPA is adding natural gas processing (NGP) facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly known as the Toxics Release Inventory (TRI), and the Pollution Prevention Act (PPA). … Membership Required You must...

This has been a huge battle in the power generation and semi-conductor industries!  To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”.  EPA has several documents making this point and for those…...

Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not…...

Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course.  Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”).  The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc…...

The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators.  This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators. …...

Today I got one of my favorite magazines, of which I have been suggesting everyone in the PSM arena subscribe to (for FREE) –  The BULLETIN from the National Board.  And in this edition, the NB has an article on the Hanson RV that has an indicator telling when the valve has been activated.  These…...

First, let me say this article was written for those who do NOT live in the world of process safety, but yet they do have hazardous materials on-site in some type of bulk system, albeit below the PSM/RMP thresholds.  In this posting, I am going to use Propane/LPG as my HAZMAT as there are many…...