Frequent Questions

Search Frequent Questions

Filter By:

Displaying 61 - 75 of 2649 results

  • Is there an exemption for the atmospheric storage of flammables?

    Under OSHA's Process Safety Management Standard, an exemption is provided for atmospheric storage of flammables. Has EPA included this exemption under the risk management program regulations? No. There is no exemption from the risk management program requirements for atmospheric storage of flammable

    • Last published:

  • Must separate amounts of regulated substances be aggregated for threshold determinations?

    Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the

    • Last published:

  • Process identification and distance between vessels

    How far apart do separate vessels have to be to be considered different processes? There is no hard and fast rule for how great this distance should be before you do not need to consider the vessels as part of one process. Two vessels at opposite ends of a large warehouse room might have to be

    • Last published:

  • Should tank capacity be considered when determining thresholds?

    When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process? The threshold determination

    • Last published:

  • Updating RMP if EPA lists a new substance

    What if EPA lists a new substance? You will have three years from the date on which the new listing is effective to come into compliance for any process that is covered because EPA has listed a new substance.

    • Last published:

  • What if the quantity in the process fluctuates?

    What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you have more than

    • Last published:

  • What does "same industrial group" mean?

    Operations at a site that belong to the same three-digit North American Industry Classification System (NAICS) code prefix (which has replaced the old SIC codes) belong to the “same industrial group. In addition, where one or more operations at the site serve primarily as support facilities for the

    • Last published:

  • Why are industries exempt under OSHA's PSM subject to RMP?

    The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA's process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management

    • Last published:

  • Do I have to conduct incident investigations of releases resulting from theft?

    The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of

    • Last published:

  • Do Program 1 processes have to complete a process hazard analysis?

    Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes

    • Last published:

  • Is a hazard review synonymous with a process hazard analysis (PHA)?

    The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention program

    • Last published:

  • Oil-filled equipment capacity

    When counting against the 1,320 aboveground storage capacity threshold, would operational storage of oil (such as in a hydraulic press) be used? Oil which is contained in equipment is required to be factored into the storage capacity for the facility even though the oil may be only used for

    • Last published:

  • Underground Storage Tanks in SPCC Plans

    If a gas station that has less than 42,000 gallons completely buried oil storage capacity and no aboveground oil storage capacity installs a new aboveground tank with a capacity greater than 1,320 gallons, must the facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan address the

    • Last published:

  • Examples of an agent of a Professional Engineer

    Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) or an agent of the PE must visit and examine the facility before the PE certifies an SPCC Plan (40 CFR §112.3(d)). What are some examples of an agent of a PE? An agent of a PE might include an engineering

    • Last published:

  • What is a farm for purposes of the SPCC Rule?

    In the December 2006 amendments to the SPCC Rule, EPA defined a farm as "a facility on a tract of land devoted to the production of crops or raising of animals, including fish, which produced and sold, or normally would have produced and sold, 1,000 or more of agricultural products during a year."

    • Last published:
Subscribe to the RSS feed for this search