PT Notes
PT Notes is a series of technical notes on process safety issued periodically by Primatech.
EPA RMP Rule Amendments 2024
Process Safety
- Part 3 - Examples of Causes of Dependent Failures in Processes
- Part 2 - Challenges in Addressing Dependent Failures in Process Safety
- Part 1 - Understanding Dependent Failures in Process Safety
- Part 2 - Are you Addressing Functional Resonance in Process Safety?
- Part 1 - Are you Addressing Functional Resonance in Process Safety?
- Enhance Process Safety with Resilience Engineering
- CSB Recommendations on Reactive Hazards to EPA and OSHA
- 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
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
