By Lee Vail

Both OSHA’s Process Safety Management (“PSM”) and EPA’s Chemical Accident Prevention regulations are regulatory programs developed to address process safety in the “Process Industry.” A “Process” is defined broadly and includes any activity that uses, stores, manufactures, handles or moves hazardous chemicals. Since the definition is broad, it includes much more than

Safe upper and lower limits are intended to relate to the equipment itself. For example, a process circuit will have multiple pieces of equipment within the circuit with varying design maximum pressure ratings. Whereas each piece of equipment will have different pressure rating, the safe upper limit for the circuit should be something less than

RAGAGEP is an acronym for the term “Recognized and Generally Accepted Good Engineering Practice.” Although this term is not defined in the PSM or RMP regulations, it is found within the Process Safety Information (PSI) and Mechanical Integrity sections. Significant controversy exists around the term and its meaning resulting, in part, in recent

Both PSM and Program 3 of RMP require compliance with similar elements which include the:

  • accumulation of process safety information (“PSI”),;
  • some type of hazard analysis (“PHA”);
  • operating procedures;
  • training, mechanical integrity (“MI”);
  • management of change (“MOC”);
  • pre-startup reviews (“PSR”);
  • compliance audits;
  • incidents investigations;
  • employee participation

For more information, contact Lee Vail.

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