PCI' PSM and RMP Digest

June 21, 1999 was the deadline for filing initial RMP's for those processes in operation at that time. The RMP must be resubmitted every 5 years, so this year, 2009, all those RMP's that were filed in 1999 will be due for re-submittal.

The EPA is making things somewhat easier by releasing software for online submittal. But, there is still an amount of work that must be done to properly file the information. All of the 14 elements of PSM must be reviewed to assure that all the information is up to date and accurate. It may be possible that your audit or PHA will need to be updated prior to submittal. Get started now to assure all your information is up to date and accurate.

If your ammonia inventory has changed, your worst case and alternative case scenarios may change, which in turn effects the toxic endpoint radius, which could change the estimated population.

If you need any assistance, send us a note or call, and we can help assure your information is accurate and on time.

I don’t quote any code or regulation without using the code or regulation as a guide. I learned early in my career that as soon as I utter the words “the code says….” someone would actually open the book I was referring to and point out some mistake. Even today, with all of the talking and interpreting and consulting, I will find that when I read the actual text, I see words that put an entirely different spin or interpretation on the topic at hand.

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With the year’s end just around the corner, now may be a good time to review your PSM program and assure that all the things you’re supposed to do have been done. A lot of little tasks can be overlooked and cause a finding during your compliance audits. Have your operating procedures been reviewed and certified? What about your three year refresher training? And there could be some mechanical integrity issues out there, too. Did all this year’s MOC’s get closed out? The final review or signatures can often be overlooked.

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A lot of effort and resources have been spent by companies on PSM programs and implementation only to have the program fall to the wayside when personnel changes occur. We witness many programs that must be completely restarted from the ground up only because continuity is lost when a key person responsible for PSM leaves that role.

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EPA has announced that RMP*eSubmit will become available in early 2009. If you have filed an RMP, you will receive notice for the changes and how to obtain the new software.

So one of the last official uses of those pesky floppies will come to an end, and we will all be able to submit easier, faster, and more reliably, (not that reliability has been an issue)

A fact sheet for the new application can be downloaded here at http://www.epa.gov/OEM/docs/chem/RMP2009Reporting.pdf