PSM and EPA Risk Management Program compliance, reactive chemistry hazard review, RCRA generator obligations and the mechanical integrity work that actually consumes the effort.
Process changes made under commercial pressure without a documented MOC are the single most common contributing factor in serious chemical incidents. Temporary changes that quietly became permanent are the classic pattern.
Inspection and test schedules for covered equipment with defined acceptance criteria, documented results and deficiency correction. This element consumes more labor than the rest combined and is the most commonly deficient.
Incompatible material combinations, thermal stability and runaway potential frequently have no documented assessment, particularly for processes developed in house over time.
Piping diagrams that do not match the field, relief system design basis missing or unverifiable, and chemical data assembled once and never revisited.
Open recommendations from a hazard analysis conducted years ago are close to indefensible after an incident, and they are extremely common.
Generator status, accumulation time, container management, tank standards and contingency planning all scale with volume. Status changes go unnoticed until an inspection.
Applicability first — PSM, RMP and RCRA generator status documented rather than assumed. Then the three elements that produce the incidents: process safety information accuracy, mechanical integrity, and management of change with a pre-startup review that actually gates startup.
We facilitate PHAs and revalidations with your operations and maintenance people in the room, run the three-year compliance audit with a closure process, and build the RCRA program alongside it because the same personnel carry both.
They overlap substantially but are not identical, with different covered chemicals, thresholds and an offsite consequence analysis and public reporting requirement under RMP. Build them together, maintain the differences deliberately.
At least every five years, and revalidation must genuinely account for changes since the last study rather than restating it.
Mechanical integrity documentation — inspections performed without recorded acceptance criteria and results, or deficiencies identified and never closed.
Yes. Facilitation with your own operators and maintenance personnel in the room is where the value is; a study run only with engineering misses how the plant actually runs.
In scope. Dust hazard analysis, ignition control, dust collection design and housekeeping are assessed alongside the process safety work rather than separately.
Twenty minutes to establish what you are covered by and how many recommendations are still open.
Exposure assessment and surveillance for chemical operations.
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