Want to be the next news story defending a weak interpretation?

Last week, a client asked about PSM / RMP applicability which had me dig up some applicability assessments BPS performed in the past. It reminded me, that between Wynnewood, letters of interpretation, and industry group communications the whole process is as clear as the Mississippi River (that’s murky for those of you who don’t know). Here are some things to consider when evaluating:

1. Interconnectivity - Review non-regulatory systems interconnected to regulatory systems. Utilities and auxiliary systems may become covered due to interconnectivity. See interpretation letters and court cases.

2. Failure Principal - Determine how many failures are necessary to make something deemed not credible. Don't just rely on the hazard not being there during normal operation.

3. Co-location - Could failures of non-regulatory equipment impact regulatory equipment due to co-location

4. Aggregation - If evaluating OSHA applicability, you may need to aggregate co-located flammables for determination.

5. 1% rule - 1% of a hazardous chemical could constitute an entire mixture being considered in your applicability assessment.

Comment with some additional tips that you use to review your facility.

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