PT Notes

EPA RMP Rule Amendments 2024

• EPA RMP Rule 2024 Amendments - Overview
• EPA RMP Rule 2024 Amendments - Power Loss
• EPA RMP Rule 2024 Amendments - Natural Hazards
• EPA RMP Rule 2024 Amendments - Process Safety Information and Availability of Hazard Evaluation Information
• EPA RMP Rule 2024 Amendments - Emergency Response
• EPA RMP Rule 2024 Amendments - Employee Participation
• EPA RMP Rule 2024 Amendments - Root Cause Analysis
• EPA RMP Rule 2024 Amendments - Third-Party Compliance Audits
• EPA RMP Rule 2024 Amendments - Availability of Information to the Public
• EPA RMP Rule 2024 Amendments - STAA Technology Transfer
• EPA RMP Rule 2024 Amendments - STAA Safeguard Implementation
• EPA RMP Rule 2024 Amendments - STAA Practicability Assessment
• EPA RMP Rule 2024 Amendments - STAA Performance
• EPA RMP Rule 2024 Amendments - STAA Requirements
• EPA RMP Rule 2024 Amendments - Areas of Technical Clarification / Enforcement Issues
• EPA RMP Rule 2024 Amendments - Risk Management Plan
• EPA RMP Rule 2024 Amendments - Stationary Source Siting
• EPA RMP Rule 2024 Amendments - Compliance Dates
• A Perspective on the 2024 Amendments to EPA's RMP Rule

Process Safety

• What is a PHA Planning Package?
• A Hidden Risk: How Creeping Changes Threaten Process Safety
• Disasters are Rarely Failures of Knowledge - Part 2
• Creative Thinking is Vital in Process Safety
• Critical Thinking is Vital in Process Safety
• How Should Cybersecurity Risk Assessment Be Performed?
• Are You Addressing the Risks of Simultaneous Operations in Your Facility?
• Are Technological Approaches to Education and Training Appropriate?
• Can Cognitive Biases Cause Process Safety Incidents?
• 6 Reasons to Use PHA Software
• How to Perform Dust Risk Assessment
• Damage Mechanism Reviews and Process Hazard Analysis
• Field Tour for PHA
• What Companies Should Look for in a PHA Facilitator
• Hazards of Cold Weather Process Operations
• A Strategy for Developing Risk Reduction Measures in PHA
• What Companies Should Look for in a Process Safety Auditor
• Improve the Quality of Your PHA Studies by Using Protocols
• Learning from Training
• Lessons Learned from Combustible Dust Fires and Explosions
• How to Tell Your PHA/LOPA Facilitator is Competent
• Maximize the Value of Your PHA Studies By Using Analytics
• The Importance of Lifelong Learning
• Effectively Conduct Remote PHA/HAZOP Studies
• How to Tell Your Process Safety Auditor is Competent
• How to Conduct a Process Hazard Analysis (PHA) Efficiently and Effectively
• Disasters are Rarely Failures of Knowledge - Part 1
• The 10 Less Recognized Benefits of PSM
• How Process Safety Supports a Company's License to Operate
• Process Safety is an Investment in Operational Excellence
• Beyond Compliance: How Process Hazard Analysis (PHA) Drives Operational Excellence and Business Value
• Managing Aging Assets in Process Plants
• Addressing Safety Critical Actions In Process Safety Management
• The Importance of Defining the Process Boundaries for PHA Studies
• Inherent Safety Review
• What is the difference between RAGAGEP and Codes and Standards?
• Part 4 - Methods for the Identification of Dependent Failures in Processes
• Enhance Process Safety with Resilience Engineering
• Part 1 - Are you Addressing Functional Resonance in Process Safety?
• CSB Recommendations on Reactive Hazards to EPA and OSHA
• Part 2 - Are you Addressing Functional Resonance in Process Safety?
• Part 2 - Challenges in Addressing Dependent Failures in Process Safety
• Part 1 - Understanding Dependent Failures in Process Safety
• Part 3 - Examples of Causes of Dependent Failures in Processes
• CSB Recommendations on SIMOPs to OSHA and CCPS
• Are your PHA worksheets data lakes or data swamps?
• Leadership Skills for PHA Facilitators - Managing Teams
• Big Data and Process Safety
• Safeguards Bypass Analysis Using LOPA
• Should you address misoperation or maloperation in PHA?
• PHA Practices to Avoid - Vague references
• PHA Practices to Avoid - Improper Recording of Safeguards
• Prevention versus Mitigation Barriers in Bow Tie Analysis
• PHA Practices to Avoid - Undocumented and invalid assumptions
• Leadership Skills for PHA Facilitators - Managing Conflict
• Leadership Skills for PHA Facilitators - Managing Conflict - Part 2
• Leadership Skills for PHA Facilitators - Examples of Managing Conflict
• Leadership Skills for PHA Facilitators - Rules of the Road and Ground Rules
• Using the Hierarchy of Hazard Controls to Guide the Selection of PHA Recommendations
• The Importance of Approvals in PHA Studies
• The Importance of a Charter for PHA Revalidation
• PHA Health Check - Omissions and Deficiencies
• Human and Organizational Factors in Bow Tie Analysis
• Issues With Human Safeguards
• A Strategy for Ensuring Human Process Safeguards are Reliable and Effective
• Who Should Use PHA Data Analytics?
• Is your facility prepared for natech incidents?
• Addressing Modes of Operation in Process Hazard Analysis (PHA)
• The Importance of Diversity for Redundant Safeguards
• Challenges in Constructing Bow Tie Diagrams - Degradation Factors and Controls
• Challenges in Constructing Bow Tie Diagrams - Barriers
• Challenges in Constructing Bow Tie Diagrams - Threats and Consequences
• What is the Difference Between a Hazard and a Top Event in Bow Tie Diagrams?
• Challenges in Constructing Bow Tie Diagrams - Hazards and Top Events
• Dangers of Using PHA Templates
• What is the Difference Between a Barrier and a Control in Bow Tie Diagrams?
• The Importance of Information Needs in PHA
• Creative Thinking in Process Safety
• Guidelines for Creative Thinking in Process Safety
• Overcoming Obstacles to Creative Thinking in Process Safety
• PHA Practices to Avoid: Pre-Entry of Data
• What Distinguishes a Barrier from a Control in Bow Tie Diagrams?
• PHA Practices to Avoid: Improper Use of Checklists
• Barrier Management Using Bow Tie Diagrams
• PHA Practices to Avoid - Improper Worksheet Entries
• Safety Metrics for Process Hazard Analysis (PHA)
• Quality Metrics for Process Hazard Analysis (PHA)
• Managing Process Safety During the Pandemic
• Discretion in Enforcement of OSHA Standards During the Pandemic
• Relationship of Bow Tie Analysis (BTA) to Process Hazard Analysis (PHA)
• HAZOP Practices to Avoid: Parameter-First Approach versus Guideword-First Approach
• Worst-Case Scenarios in Process Hazard Analysis (PHA)
• Role of Limiting Conditions for Operation in PHA
• PHA Analytics
• Uses of Bow Tie Diagrams in Process Safety
• Causes of Process Safety Incidents
• Cognitive Biases in PHA
• Use of Risk Matrices in Process Safety
• PHA for Reactive Chemical Hazards
• Addressing Design and Engineering in Process Safety
• Multiple Failures in PHA
• New Jersey TCPA Risk Tolerance Criterion
• Addressing Weaknesses in HAZOP Studies
• Competency Requirements For PHA Teams
• Allocation of Risk Tolerance Criteria
• Managing Competency for Process Safety
• What is PHRA?
• Risk Tolerance Criteria Offsets in SIL Determination
• The Impact of Risk Uncertainties on SIL Determination
• The ALARP Principle in Process Safety
• Common Cause Failure in SIL Determination
• Use of Risk Matrices and Risk Graphs for SIL Determination
• Risk Tolerance Criteria and Safety Instrumented Systems
• Design Intent for HAZOP Studies
• PHA Team Member Roles That May Be Overlooked
• Chemical Reactivity and HAZOP Studies
• Competency Requirements for Process Safety Auditors
• Managing Process Risks
• Addressing Inherent Weaknesses in PHA
• Initiating Events, Level of Causality and PHA
• Importance of Defining the PSO for PHA Studies
• Terminology for PHA
• Meaning of Process Safety Management
• Pitfalls in Addressing Chemical Reactivity Hazards in PHA
• Addressing Enablers in LOPA
• Choosing Scribes for PHA Studies
• Calibration of Risk Matrices
• Addressing Domino Effects in PHA
• Completeness of Scenario Identification in PHA
• Common Mistakes in Using Risk Tolerance Criteria with LOPA
• Engineering Judgment and Expert Opinion in Hazard and Risk Analysis
• Damage Mechanism Reviews
• Qualifying Safeguards as IPLs for LOPA
• Designing Risk Matrices
• Cyber Attacks on Computer Control Systems
• Hazards Addressed by Process Safety
• Black Swan Events and Process Safety
• Process Safety Incidents, Safety Goals, and Risk Tolerance Criteria
• Process Safety Incidents and Standards for Process Safety Elements
• Process Safety Incidents in Aging Plants
• Safeguard Failures Can Be Initiating Events and Enablers
• Uncertainty and Subjectivity in Using Risk Matrices
• HAZOP Practices to Avoid: Consequence-Before-Cause Approach
• HAZOP Practices to Avoid - Cause-By-Cause (CBC) Versus Deviation-By-Deviation (DBD) Recording
• HAZOP Practices to Avoid - Use of Super Nodes
• HAZOP Practices to Avoid: Deviation-Centric Studies
• PHA for Phases of Operation in the Process Lifecycle
• Determination of Safety Integrity Levels (SILs) Using Layers of Protection Analysis (LOPA)
• Pre-work and Pre-completion for PHA
• Process Safety Incidents and Competency
• Validating Safeguards for PHA
• Hazard Analysis Using Simultaneous Operation (SIMOP) Review
• Process Safety Competence and the IEC 61511 Standard
• LOPA for SIL determination
• Risk Tolerance Criteria for LOPA
• Conducting PHA to Facilitate LOPA
• Risk Reduction Measures in PHA
• Contributions to Risk Reduction from SIS and Non-SIS Systems in SIL Determination
• Human Factors in the Performance of PHA and LOPA Studies
• Chemical Safety Board Recommendations on Using the Safety Case Regime in the US
• Critical Thinking in Process Safety Management
• Understanding HAZOP Deviations

EPA RMP Rule Amendments 2022

• Amendments to EPA's RMP Rule - Safer Technologies and Alternatives Analysis
• Amendments to EPA's RMP Rule - Root Cause Analysis
• Amendments to EPA's RMP Rule - Third-Party Compliance Audits
• Amendments to EPA's RMP Rule - Employee Participation
• Amendments to EPA's RMP Rule - Emergency Response
• Amendments to EPA's RMP Rule - Information Availability
• Amendments to EPA's RMP Rule - Technical Clarifications
• Amendments to EPA's RMP Rule - Compliance Dates
• Amendments to EPA's RMP Rule - Treatment of Declined Recommendations
• Amendments to EPA's RMP Rule - Natural Hazards and Loss of Power
• Overview of EPA's Proposed Changes to the RMP Rule
• Amendments to EPA's RMP Rule - Stationary Source Siting

OSHA PSM

• Changes to OSHA's PSM Standard
• New OSHA NEP for PSM-Covered Facilities

OSHA RFI

• OSHA RFI - Revisions to the PSM Standard - OSHA's Request for Information
• OSHA RFI - Coverage of the Storage of Flammables in Atmospheric Tanks
• OSHA RFI - Oil-Well and Gas-Well Drilling and Servicing and Production Facilities
• OSHA RFI - Coverage and Requirements for Reactive Hazards
• OSHA RFI - Updating the List of Highly Hazardous Chemicals and Policy Change on Listed Chemicals Without Specific Concentrations
• OSHA RFI - Additional Management System Elements
• OSHA RFI - Defining and Evaluating Updates to RAGAGEP
• OSHA RFI - Expanding the Scope of Mechanical Integrity and Management of Change Requirements
• OSHA RFI - Changes to Compliance Audit Requirements

EPA RMP Rule Amendments

• EPA RMP Rule Amendments - Emergency Response Preparedness
• EPA RMP Rule Amendments - Summary
• EPA RMP Rule Amendments - Availability of Information to the Public
• EPA RMP Rule Amendments - Incident Investigation
• EPA RMP Rule Amendments - Hazard Review and Process Hazard Analysis
• EPA RMP Rule Amendments - Safer Technology and Alternatives Analysis
• EPA RMP Rule Amendments - Third-Party Compliance Audits
• EPA RMP Rule Amendments - Compliance Audits
• EPA RMP Rule Amendments - Risk Management Plan Streamlining, Clarifications, and Technical Corrections

Proposed Changes to EPA RMP Rule

• Proposed Amendments to EPA's RMP Regulation
• Synopsis of EPA's Proposed Amendments to the RMP Rule
• Stationary Source Location and Emergency Shutdown
• Incident Investigation Root Cause Analysis
• Third Party Audits
• Safer Technology and Alternatives Analysis
• Emergency Response Preparedness Requirements
• Information Availability Requirements
• Risk Management Plan Streamlining, Clarifications, and RMP Rule Technical Corrections Plus Compliance Dates

EPA RFI

• EPA RFI - Updates to the List of Regulated Substances
• EPA RFI - Additional Risk Management Program Elements
• EPA RFI - RAGAGEP, Mechanical Integrity of Safety-Critical Equipment, and Management of Organizational Changes
• EPA RFI - Third-Party Compliance Audits
• EPA RFI - Effects of PSM Coverage on RMP Applicability
• EPA RFI - Safer Technology and Alternatives Analysis
• EPA RFI - Emergency Drills
• EPA RFI - Automated Release Detection and Monitoring
• EPA RFI - Additional Stationary Source Location (Facility Siting) Requirements
• EPA RFI - Compliance with Emergency Response Program Requirements
• EPA RFI - Incident Investigation and Accident History Requirements
• EPA RFI - Worst-Case Release Scenario for Multiple Small Vessels
• EPA RFI - Public Disclosure of Information
• EPA RFI - Threshold Quantities and Off-Site Consequence Analysis Endpoints
• EPA RFI - NAICS Codes Based on RMP Accident History Data
• EPA RFI - Safety Case Regulatory Model and Streamlining RMP Requirements

Executive Order Status Report

• Executive Order Status Report - Strengthening Community Planning and Preparedness
• Executive Order Status Report - Enhancing Federal Operational Coordination
• Executive Order Status Report - Improving Data Management
• Executive Order Status Report - Modernizing Policies and Regulations
• Executive Order Status Report - Incorporating Stakeholder Feedback and Developing Best Practices
• Executive Order Status Report Highlights - Modernizing OSHA's PSM Standard to Improve Safety and Enforcement
• Executive Order Status Report Highlights - Modernizing EPA's RMP Regulation
• Executive Order Status Report Highlights - Promoting Safer Technology and Alternatives
• Executive Order Status Report Highlights - Guidance and Outreach to Help Industry Understand Requirements and Best Practices
• Executive Order Status Report Highlights - Capturing Best Practices
• Executive Order Status Report Highlights - Increasing OSHA Penalties