This process is covered. DOE contractors may wish to adopt the following approach.
Extend the boundary upstream and downstream to the point at which there is no
reasonable potential for a catastrophic release. At least the equipment immediately
upstream and downstream from the vessel containing the TQ of the HHC should be
included in the boundaries of the process.
A batch process uses an HHC, above its TQ, in one of its many processing steps. Is
this step, and its associated equipment, a covered process?
Yes. In addition, the same strategy discussed in Questions 30 and 31 may apply to the
equipment used in a batch process. A DOE contractor may apply a similar approach in
setting the boundaries around the processing steps that are covered under the Rule.
Must the inventory of HHCs contained in offsite interconnecting pipelines be
included in the inventory calculation? If so, can reliable isolation devices at the
fence line be used to limit the inventory used in the coverage calculation?
DOE contractors should consider the amount of material that could reasonably be
released if a loss of containment occurred onsite. If this amount represents a catastrophic
release to the workplace (i.e., it exceeds the TQ for an HHC), then the process is covered.
OSHA has not yet recognized the use of isolation devices as adequate mechanisms to
limit inventories for purposes of determining coverage under the PSM Rule. However, if
isolation devices are considered as preventative or mitigative control measures against
catastrophic releases, then documentation should be provided as to their effectiveness and
Does the PSM Rule apply to laboratory and research operations?
A laboratory or research operation involving at least the TQ of one or more HHCs is
subject to the PSM Rule.
Does the PSM Rule apply to EPA regulated and permitted Resource Conservation
and Recovery Act (RCRA) hazardous waste treatment, storage, and disposal (TSD)
facilities, when such facilities keep onsite in one location a hazardous waste chemical
in a concentration and quantity that exceeds the applicable TQ of Appendix A.
Yes. Contractors having TSD facilities which contain covered processes must comply
with the PSM Rule.