It can be a challenge for owners of facilities that use hazardous chemicals that need to address process safety to understand the nuances of legal requirements, to meet requirements, and to conduct necessary periodic activities internally without assistance. Many facility owners do not have internal resources qualified to address the safety of their highly hazardous chemical processes without assistance.
The Occupational Safety and Health Administration's (OSHA) 29 CFR 1910.119, the Process Safety Management (PSM) Standard, and the Environmental Protection Agency's (EPA) 40 CFR Part 68 Risk Management Program (RMP) require the development and implementation of a system of procedures aimed at preventing accidental releases of hazardous chemicals from subject processes. Facilities with processes that contain greater than a threshold quantity (TQ) of a listed substance must meet these requirements. Some requirements include preparing procedures to address employee participation, management of change, and operations as well as conducting a comprehensive process hazard analysis (PHA) designed to identify and address hazards in the process. In addition to the "prevention program" requirements of both regulations, the RMP regulation requires performance of an Offsite Consequence Analysis and submittal of the facility's RMP summary to the U.S. EPA initially with updates at 5-year intervals.
Related to these requirements, addressing the safe management of chemicals and prevention of chemical releases is also the subject of EPA's General Duty Clause (GDC), established in the Clean Air Act Section 112 (r)(1). The GDC requires facilities with hazardous chemicals in process, regardless of quantity, to "identify hazards which may result from releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur." The means for meeting these requirements are similar to what is required under the PSM Standard and RMP Rule.
To help address these needs, Geosyntec offers the following related services:
- Developing or updating customized prevention programs, including "lite" programs that address the GDC;
- Providing on-call "Help-Desk" assistance related to PSM/RMP compliance;
- Conducting RMP and PSM internal periodic audits (every three years);
- Facilitating PHAs (HAZOP, What-If, and Checklist methodologies);
- Preparing offsite consequence analyses (OCAs);
- Preparing RMP submittals (5-year submittal cycle);
- Assisting with the development of operating procedures;
- Assisting with compliance program development related to safe work practices such as hot work, confined space, and lockout/tagout;
- Helping to prepare for regulatory audits and assisting with consent orders;
- Preparing emergency action or emergency response plans; and,
- Delivering customized training (PSM/RMP fundamentals, auditor training).
Process experience examples include refrigeration (anhydrous ammonia), power (aqueous ammonia and anhydrous ammonia used for control of nitrogen oxides, chlorine used for cooling tower water treatment, motive fluids used in geothermal power), water treatment (chlorine for disinfection and sulfur dioxide for chlorine removal), chemical manufacturing (flammable liquids and gases as well as toxics), and refineries (flammable liquids and toxics.)
Our practitioners have deep experience working with a variety of industries in developing programs to comply with these regulations, including the necessary documentation, process hazard analyses, consequence analysis modeling, and audits.