2020有需要变化和adaptability on many levels. To abate the many risks posed by the pandemic, many facilities have started to explore additional service lines or processes, which means an entirely new set of equipment, chemicals, and employees. These additions create an additional set of hazards to mitigate in the workplace.
如果您的企业今年早些时候推动了制造实践，您现在可以面临安装和实施与易燃液体储存相关的设施的困境。您是否知道您是否拥有适当的允许或计划，以遵守适用的规则和规定继续生产？
Applicability and Exceptions
We will discuss a few scenarios focusing on the applicability of OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Planning (RMP) standard.
Let’s assume that you setup your flammable liquid storage tank, blending tank, and new process line. You are ready to start production. Now what do you do?
It is obviously recommended to determine what rules apply prior to installing new equipment, but if you are determining applicability at this point in the process, it is just as critical to determine what don’t apply to you (and why).
设置易燃液体储罐和用于您的流程的混合罐可以将您的新线路通往职业安全和健康管理（OSHA）的高度危险化学品标准的过程安全管理（29 CFR 1910.119）。在PSM标准下，OSHA已经确定了一种涉及易燃液体的过程，沸点在100,000磅的100磅以上的100华氏度以下。或者更多是受标准的约束。
Are there any exceptions if your storage is greater than 10,000 lbs?
如果液体储存在大气罐中并且不冷却或冷藏以保持在其沸点以下，则可以从PSM标准中排除罐。OSHA将大气罐定义为储罐，该储罐被设计成在大气压下通过0.5 p.i.g的压力操作。（每平方英寸磅，3.45 kPa）。
Additionally, although your storage tank may meet the exception above; once you transfer the flammable liquid to the blend tank, the blend tank will be subject to the standard if the quantity is 10,000 lbs or greater.
What about the RMP standard?
If you fall under the OSHA PSM standard, you fall under the EPA RMP program 3; however, if you do not fall under the PSM standard, then you would not fall under RMP.
The EPA has a different way of determining what flammable liquids are subject to the standard. If the flammable liquid in question is either ethanol or isopropanol (IPA), neither are listed by EPA as they have determined that only flammables listed by the National Fire Protection Agency (NFPA) as Category 4 flammables are subject to the rule. Both ethanol and IPA are NFPA category 3 flammables. In this situation, you have avoided regulation under PSM or RMP standards; however, suppose you install a blend tank to blend 10,000 lbs or more of flammable liquid? Then you would be included in the PSM standard.
Implementing Management of Change
One way to identify potential regulatory issues is by having a Management of Change (MOC) system in place. Although an MOC process is only required by the PSM and RMP standard, having an MOC process can keep your facility compliant with the many rules and regulations that might apply. An MOC process will help in identifying new chemicals, new hazards and risks, and new permitting or reporting requirements before you make changes to your facility.
An MOC process is important to have before you purchase or initiate construction to prevent unintended consequences associated with your change. During the MOC process you may identify air, stormwater, and wastewater permitting issues, new waste stream characterizations and classifications, and Emergency Planning and Community Right-to-know Act (EPCRA) Section 312 and 313 reporting. If you encounter these issues or requirements, Braun Intertec can help. For more information, read
“Using the Right Tools for your RPM/PSM Hazard Assessments”.
In a live, free webinar on November 19th, industrial hygiene and safety professionals, Nick Foreman, CSP, and Conan Reed, GSP, will discuss the applicability and exclusion criteria, the differences and commonalities between the two programs, some of the core and crucial definitions, steps and components of the programs, and some helpful lessons-learned from their RMP/PSM experience.