RMP was promulgated a few years after PSM and kept the same list of PSI developed by OSHA. See 29 CFR 1910.119(d) and 40 CFR 68.65. Although basically the same list, EPA’s list dropped reference to the health and safety of employees (as they lack authority to regulate the workplace). See 61 Fed. Reg. 31668, 31711 (June 20, 1996). Information concerning the hazards of the regulated materials is required; sufficient information is typically found in a material safety data sheet (MSDS). Also included in the PSI requirement is information about the technology of the process. These include:

  • A block flow diagram or simplified process flow diagram;
  • Process chemistry;
  • Maximum intended inventory;
  • Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and,
  • An evaluation of the consequences of deviations.

Other PSI required involves the equipment in the process. These include:

  • Materials of construction;
  • Piping and instrument diagrams (P&ID’s);
  • Electrical classification;
  • Relief system design and design basis;
  • Ventilation system design;
  • Design codes and standards employed;
  • Material and energy balances for processes built after June 21, 1999; and
  • Safety systems (e.g. interlocks, detection or suppression systems).

Finally, PSI includes two less defined requirements; documentation that equipment complies with recognized and generally acceptable good engineering practices (also referred to a “RAGAGEP”) or alternatively, where equipment was constructed to older versions of a code or standard, the employer must document that “equipment is designed, maintained, inspected, tested, and operated in a safe manner.” 29 CFR 1910.119(d)(3)(iii) and 40 CFR 68.65(d)(3).

OSHA originally proposed that PSI must be communicated to employees. This explicit requirement was removed when the rule became final. However the requirement implicitly remains based on requirements for employee participation, contractors and training. 57 Fed. Reg. 6356 ,6374 (Feb 24, 1992).

For more information, contact Lee Vail.

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