A number of years ago a former client decided that process safety was not worth the effort and wanted to get their process below the 10,000 pounds TQ for their LPG. They hired a local architect/engineering firm that had no experience with the storage, handling, and processing of LPGs. This “architect/engineering firm” advised the facility that no MOC would be necessary; later admitting they really did not understand the role of the MOC process and the PSM/RMP requirements. A couple of years later I get a phone call from a friend at a regulatory agency asking me about my PHA(s) and Audits I had done for the facility. Seems the facility completed their change and had gotten the process done to less than 10,000 pounds, but the manner in which they (and their architect/engineering firm) did it may have led to a significant LOPC event. The case got settled last year and so now I can write about it without revealing who and where it happened. There are some excellent process safety learnings from this incident, most notably how a MOC procedure may prevent such an event and how even a reduction in inventory may not be as simple as flipping a switch to make PSM/RMP go away.
The process was a fairly small and simple process that involved an LPG. Years before the incident the business was using a lot of LPG for several of its products, but over time the demand was reduced such that the price of doing PSM/RMP was more than the cost of the products. So the business decided that it would do away with several products and focus on just two (2) which would allow for a substantial reduction in the volume of LPG – such that they could get below 10,000 pounds.
NOTE: my only involvement in this reduction project was to advise the facility that they needed to use the MOC tool and do a hazard review to ensure this change (removal from PSM/RMP) was done properly, as EPA still could hold them accountable under the CAA GDC.