Using OSHA`s requirement for the revalidation of PHA`STo comply with EPA`s proposed risk management rule

Conference · Thu Aug 01 04:00:00 EDT 1996

OSTI ID:269138

Him, M S; Mannan, M ^[1]

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1. RMT/Jones & Neuse, Inc., Austin, TX (United States)

OSHA`s Process Safety Management rule not only requires the performance of process hazards analyses (PHA`s) of covered areas, but the revalidation of these PHA`s every 5 years. With the May 26, 1997 deadline for the completion of initial PHA`s nearing and the pending approval on or before March 1996 of EPA`s Risk Management Programs (RMP) for Chemical Accidental Release Prevention ({section}40 CFR 68), PSM-covered facilities must start developing plans for compliance with one or more of the requirements of these regulations. This paper discusses some of the strategies that companies falling under Tier 3 of EPA`s RMP rule may use to comply with OSHA`s revalidation of PHA`s and the upcoming EPA rule. The paper also provides details on the use of other PSM elements for PHA revalidation (such as compliance audits and management of change), the development of schedules for PHA revalidation, preparation time, the revalidation process, and the documentation/identification of RMP hazard scenarios.

• OSTI ID: 269138
• Report Number(s): CONF-960107--
• Country of Publication: United States
• Language: English

Related Subjects

02 PETROLEUM
COMPLIANCE
HAZARDOUS MATERIALS
HEALTH HAZARDS
PETROLEUM INDUSTRY
POLLUTION REGULATIONS
RISK ASSESSMENT
SAFETY
US OSHA
VALIDATION