I am always amazed to hear people complain about the degree of our auditing. Most clients hire us for detailed auditing, but some see the PSM/RMP 3-year audits as a “check-the-box” exercise and do not appreciate our auditing skills and experience (LOL). Comments/Questions like… “Would OSHA really cite for that?” are commonplace. Let me be clear; our job is to find more than OSHA/EPA would ever find – not to reduce your compliance risks, but to ensure a safe process!
One critical item that is unfortunately not managed well is our last line of defense… relief valves. We sample a lot of Pressure Relieving Devices (PRDs) within a process to ensure they are of the right design, size, and set point. Today, most businesses have the proper type of PRD, and more and more are paying attention to their sizing scenarios. But one aspect still eludes many… weep holes and/or weather caps.
To state the fact… UG-136 Minimum Requirements for Pressure Relief Valves actually discusses “weep holes” and/or “cover or discharge piping” as being REQUIRED.