We are no longer surprised when we come across a “process” which is not a PSM-covered process because the facility has managed the quantity of their HHC below OSHA’s threshold. However, from a risk perspective, having 9,975 pounds of an HHC versus having 10,000 pounds does not lessen our process or personnel risks, but that is another discussion for a rainy day. Recently we came across an even more unique situation that nearly resulted in multiple contractors receiving serious burns when the flammable vapors ignited. The process was not covered by PSM/RMP because the “feed stock” was a Category 4 flammable liquid with a FP just under 190°F; however, this Category 4 flammable liquid was being heated to a temperature well above it’s flash point. Here’s what happened and how OSHA was at a loss to take action…

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