When developing new projects involving flammable substances, reviewing various chemical safety regulations for applicability early in the design process is important. Otherwise, technical studies and safety documentation requirements could delay project permitting and approval.
For example, climate change drives the need for alternative, low-carbon fuels such as hydrogen. Hydrogen production and storage facilities with more than 10,000 pounds on-site must comply with regulations such as:
Best Practices for RMP and PSM Compliance
First, SCS Engineers (SCS) reviews federal and state chemical safety regulations for any exemptions that may apply, including:
SCS then develops RMP, PSM, and state-compliant prevention programs as required for:
SCS recommends conducting a Hazard and Operability Study (HAZOP) for the PHA based on the American Institute of Chemical Engineers (AIChE) HAZOP Guide Word method. Guide words specify deviations from normal operating conditions or parameters and spark discussion of engineering controls, administrative controls, and emergency procedures.
In addition, SCS recommends using multiple safety checklists to review human factors, external events (including facility siting), and potential emergency planning and response procedure changes.
Where safety is lacking or needs improvement, SCS focuses on identifying appropriate mitigation measures. SCS then uses the PHA results to conduct the Hazard Assessment / Offsite Consequence Analysis for the worst-case and alternative flammable release scenarios resulting in fire or explosion.
About the Author: Dr. Lemaster is a Senior Project Manager at SCS. Dr. Lemaster is responsible for the documentation of Process Safety Management Programs (PSM), Risk Management Programs (RMP), and California Accidental Release Prevention Programs (CalARP) projects for regulated facilities using hazardous materials. She has a Bachelor’s Degree in Chemical Engineering and a Master’s and PhD in Nanoengineering from the University of California, San Diego. Contact her at or on LinkedIn.
Additional Resource: Risk Management Plans-RMP and Process Safety Management-PSM