Usage of certain hazardous chemicals is regulated by both the Environmental Protection Agency (EPA) and the Occupational Safety & Health Administration (OSHA), among others.  The OSHA regulations, under 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals, are focused on potential impacts to a facility’s employees.  EPA’s regulations, under Section 112(r) of the Clean Air Act (40 CFR Part 68), are aimed at identifying and preventing impacts outside the facility’s fenceline – protection of the community at large.  OSHA’s PSM language and terminology are consistent with EPA’s RMP regulations.  WLA works with organizations subject to these rules, and can help develop a first-time program or conduct a periodic review.

Risk Management Plans (RMP)

WLA can provide assistance with preparation of Risk Management Plans (RMP).  Facilities that are stationary sources with certain regulated substances above a threshold quantity are regulated under this standard.  EPA estimates over 100,000 facilities fall under the standard.  We can help with RMP hazard assessments, including offsite and worst-case scenario analysis, hazard reviews, and development of procedures and supporting documentation.

Process Safety Management (PSM)

WLA’s chemical engineers work with facility staff with preparation of Process Hazard Evaluation/ Analysis as described in OSHA’s PSM regulations.  We use guidelines and approaches as recommended by the Center for Chemical Process Safety (CCPS).  If needed, WLA can also assist with development of standard operating procedures, pre-startup safety reviews, management of change, compliance audits, revalidation, and other elements of a comprehensive PSM program.