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Parent Category: Safety Info Posts

Category: Chemical Process Safety (PSM/RMP)

Published: 06 August 2017

One of the most misunderstood operating procedures in OSHA’s PSM and EPA’s RMP standards is the “Initial Start-Up procedure”. OSHA, nor EPA has offered a lot of written guidance, on this requirement and this has led to a lot of confusion as to why it is called out and how this SOP differs from a “Normal Start-Up” SOP. But anyone who has a PSM (or maybe an RMP) process that handles a non-conductive flammable liquid knows all too well how the initial start-up SOP differs from their normal start-up, but I will explain…

For those who may not be familiar with “non-conductive” flammable liquids should first read the dozen or so posts in my Flammable Liquids Section so that they have a better understanding of how these flammables pose significant static risks. With that said, these flammable liquids require SPECIAL ATTENTION from both the engineers who design the process and the operators who will be transferring these flammable liquids. For the sake of time and to stay on course with this posting, I will cut to the chase. The speed at which we transfer these flammables is CRITICAL to process safety. And these speeds vary depending on the process conditions - hence “initial start-up” when the receiving storage tank is EMPTY.

Now I do have to mention a RAGAGEP that in the USA is sort of the go-to RAGAGEP for controlling static electricity flammable liquid processing:

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