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Question of the Week
  • Are railroad cars and tractor trailers containing more than the threshold quantity of a highly hazardous chemical and which remain in a facility for a period of time covered under 1910.119?

Question: Are railroad cars and tractor trailers containing more than the threshold quantity of a highly hazardous chemical and which remain in a facility for a period of time covered under 1910.119?

Answer:

Commercial railroad tank cars and commercial tank motor vehicles (CTMVs) when remaining on a worksite and used to store threshold quantities or greater amounts of specified HHCs are covered by the PSM standard. They are covered by the PSM standard to the extent that they are not covered another regulatory authority. For example, the Hazardous Material Regulations of the Department of Transportation (DOT) (see 49 CFR Subchapter C and particularly, Part 177-Carriage by Public Highway) cover CTMVs. These DOT regulations cover cargo tank design, construction, maintenance (including repairs) and certain operations of CTMVs. Generally speaking if the cars are considered "in transit" by DOT, OSHA will defer jurisdiction to DOT.

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Specialists in Safety, Security and Risk

Primatech specializes in Safety, Security and Risk Management for the process industries. We offer consulting, training courses, webinars, and software to assist our clients in identifying and reducing the risk of catastrophic accidents posed by hazardous materials used in their operations. Our services and products help companies to protect employees, the public and the environment as well as prevent damage to facilities, process equipment and company reputations, and improve productivity and quality. We help companies comply with the OSHA Process Safety Management (PSM) standard, EPA Risk Management Program (RMP) rule, and other government regulations, industry guidelines and requirements.

Our capabilities include:

  • Process Hazard Analysis (PHA), e.g., HAZOP Studies
  • Layers of Protection Analysis (LOPA)
  • Safety Instrumented Systems (SIS) - IEC 61511 / ISA 84
  • SIL Verification
  • PSM and RMP Compliance Audits and Program Assessments
  • OSHA Chemical National Emphasis Program (NEP) Audit Preparation and Assessment
  • PSM Program Development and Implementation
  • RMP Program Development and Implementation
  • Mechanical Integrity Program Development and Implementation
  • Mechanical Integrity Program Audits and Assessments
  • Management of Change (MOC) for Process Safety
  • Operating and Maintenance Procedures Development
  • Human Factors and Human Error Analysis
  • Facility Siting Analysis
  • Dispersion and Consequence Modeling
  • Probability Modeling
  • Quantitative Risk Assessment
  • Emergency Response Program Development and Implementation
  • Cyber Security Management
  • Process Security Management
  • Security Vulnerability Analysis for Deliberate Acts Including Terrorism
  • Expert Witness Testimony and Litigation Support

Primatech is an independent company with no vested interests and is seen, therefore, to deliver work recognized as objective and unbiased.

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