(54bb) Managing Risks Under Legal Thresholds

A key part of the initial assessment for determining a facility’s applicability for the implementation the Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (PSM) standard and/or the United States Environmental Protection Agency’s (USEPA’s) Risk Management Plan (RMP) rules is to evaluate if the facility handles, stores, uses, or manufactures any of the listed chemicals exceeding an established threshold quantity. A common trend among facilities that have covered chemicals is to implement controls to ensure that they maintain these quantities below these established thresholds. Although this practice is common in industry, we often see companies stretching the limits of the threshold quantities by fractions of a percent, or using the OSHA atmospheric storage tank exemption for flammable liquids (Meer Decision) to avoid the legal obligation to implement PSM/RMP. However, OSHA and the USEPA can still hold the facility liable for not controlling an identified risk under the General Duty Clause. Facilities can struggle with managing these risks if they are not subject to the elements of the PSM/RMP rules. To mitigate these risks, Facilities can begin to implement key elements of the PSM/RMP rules to assist in controlling the hazards associated with highly hazardous chemicals. Some Recognized and Generally Accepted Good Engineering Practice standards such as the International Institute of Ammonia Refrigeration have developed codes on how to manage the risk associated with ammonia refrigeration if you do not meet the threshold quantities for PSM/RMP. This presentation looks at the key elements required to get facilities started in implementing a management system that caters to their specific needs based upon the complexity of their process.

-Brian Desrosiers, CSP, OHST