New twist in DOT unloading/loading and PSM/RMP Threshold Determination
For years now OSHA and EPA have taken similar approaches to how they view DOT containers (Tank Trucks and Railcars) when they are connected to a process. Both agencies have stated that as long as the motive power (e.g. tractor or locomotive) remains in place then the unloading falls under DOT and thus the content in the DOT container does NOT have to be counted towards our Threshold Determination. However, "drop the trailer/railcar" then we have to view the DOT container as a process vessel/storage vessel and consider its contents towards our Threshold Determination. Keep in mind that a single 55/90 Ton Railcar of Chlorine sitting on our property is in and of itself a "covered process" regardless of where it sits; however, co-locating it in near proximity may make the RCar part of the existing covered process. But recently some OSHA state plans have posed new views on this DOT application towards PSM/RMP... |
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