Ammonia safety training

February 26, 2024

RMP and PSM Compliance
RMP PSM Compliance


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:

  • Regulated substance not present;
  • Regulated substance present but below threshold quantity in a process or
  • Regulated substances used solely as fuel or retail facilities that hold flammable substances for sale as fuel.

SCS then develops RMP, PSM, and state-compliant prevention programs as required for:

  • Employee Participation
  • Process Safety Information (PSI)
  • Operating Procedures (SOPs)
  • Employee Training
  • Contractor Safety
  • Pre-Startup Safety Reviews (PSSR)
  • Mechanical Integrity (MI)
  • Hot Work Permits
  • Management of Change (MOC)
  • Incident Investigation
  • Emergency Planning and Response
  • Compliance Audits
  • Recordkeeping and Updates
  • Management Programs
  • RMP Certification
  • Process Hazard Analysis (PHA)
  • Hazard Assessments / Offsite Consequence Analysis
  • Seismic Assessment

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.


Jeanne LemasterAbout 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



Posted by Diane Samuels at 6:00 am