Chemical Process Safety (PSM/RMP)

One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT!  We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s.  But if we do not manage these inventories AND cap…...

I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was.  The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the…...

EPA attempts to define and quantify how far apart do separate vessels have to be – to be considered different processes?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”.  But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each…...

We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs).  And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we…...

OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system…. Membership Required...

Back in May 2020 and January 2021, I posted the first two parts of this three-part series on the hazards of Liquid Nitrogen.  These articles were prompted by the OSHA and State Fire Marshal cases involving fatalities at cattle and human sperm bank businesses.  Then in January of this year, we had the GA Food…...

Does OSHA’s PSM Standard, 29 CFR § 1910.119 apply to LNG export facilities? No, and here is why…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

How often do the operators within your PSM/RMP covered process(s) actually use their operating procedures?  Hourly, Daily, Weekly, Monthly, every three years during refresher training? How often do we think they should be using their operating procedures?  How many times have you pulled the SOP binder off the shelf to find it covered in dust…...

In the 2021 revisions to the National Board Part 4 – Pressure Relief Devices, the code formally recognizes the need for an “intervening valve” on the discharge side of a relief valve.  The code, section 2.5.6 allows this in the following manner:… Membership Required You must be a member to access this content.View Membership LevelsAlready...

The 2021 NBIC Draft Edition has been officially approved by the NBIC Committee. The list of major changes found below will appear in the 2021 NBIC.  The four-part set: Part 1- Installation (162 Pages) Part 2- Inspection (402 Pages) Part 3- Repairs and Alterations (312 Pages) Part 4- Pressure Relief Devices (144 Pages) will cost…...