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 the amount we allow on-site, we will get burned one day and I do not mean in the terms of OSHA or EPA finding out. Hazardous Materials have a way of making us pay more dearly than writing a check to some regulatory agency.
Quite often we find the fixed/stationary process is indeed UNDER the TQ, but we just happen to be there right after they “dropped a trailer” (tractor removed from the trailer) right next to the process and this additional quantity put the process over the TQ due to the “co-location”. And as EPA and OSHA state, today the process must be in full compliance BEFORE the TQ is achieved/exceeded…