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…
(emphasis and links by me)
What if the quantity in the process fluctuates?
I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity.
You do not need to comply with the rule and file an RMP unless you have more than the threshold quantity in a process; however, once you have more than the threshold quantity in a process, you must be in compliance IMMEDIATELY. In this situation, with fluctuating quantities, it may be prudent to file now, so you will be in compliance when your quantity exceeds the threshold.
You may also want to consider a “predictive filing” (see Chapter 9 of the General Guidance On Risk Management Programs For Chemical Accident Prevention (40 CFR Part 68) for more information on predictive filing).