This is one of the most commonly misunderstood RMP/PSM compliance issues for facilities that use rail cars as storage tanks and or use “tube trailers” as storage tanks. EPA has been clear since 1998 on how these rail cars that are hooked up to the process and those that are “stored on spurs” are to be managed in regards to RMP threshold determination and “definition of...

Clarifications and Interpretations of the PSM Standard The guidance contained in this appendix is provided for compliance assistance. This appendix contains clarifications agreed to in a settlement agreement dated April 5, 1993, between OSHA, the United Steelworkers of America, the Oil, Chemical and Atomic Workers International Union, and the Building and Construction Trades Department of the AFL-CIO....

Here is a list of questions investigators may ask to determine whether line management deficiencies affected the accident. These questions are based on the seven (7) guiding principles of an SMS. These are not intended to be exhaustive. Investigator(s) should adapt these questions or develop new ones based on the specific characteristics of the accident. The answers to the questions may be used to...

Meer Corporation (Meer) was cited on January 9, 1995, for serious and non-serious violations of numerous safety requirements for managing hazards associated with processes using highly hazardous chemicals. The standard prescribing the multiple procedures is referred to as process safety management (PSM). The serious citation also includes an item alleging violation of the machine guarding standard...