Difference in PSI Safe Upper/Lower Limits and SOPs Operating Limits
Have you ever wondered why both PSM and RMP require an employer to establish safe upper and lower limits for such items as temperatures, pressures, flows or compositions in their Process Safety Information and evaluate the consequences of deviating from these limits, including those affecting the safety and health of employees? And then in the Operating Procedures Element, the employer is required to establish operating limits and the consequences of deviating from these limits? Are these two (2) distinct requirements looking for the same data? In other words, can my PSI data match my SOP data exactly and I be in compliance with 1910.119/Part 68? Nope… and here’s why |
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