Recent Blog Posts

Ammonia Week in Review | September 4, 2020

September 4th, 2020

Ammonia can now be used as jet fuel in this week’s edition of the Ammonia Week in Review… Ammonia can Officially Work as Jet Fuel – “It would have the potential to efficiently crack the ammonia fuel using heat harvested from the jet engine through Reaction Engines’ ground-breaking heat exchangers to provide a zero-carbon fuel blend of ammonia and […]

Final RMP Rule Changes

September 1st, 2020

Rule Changing Background In 2017, several RMP rule changes were proposed, which we previously covered. On November 20, 2019, the EPA administrator, Andrew Wheeler, signed the final Risk Management Program Reconsideration final rule. The EPA says this about the change: “[It] modifies and improves the existing rule to remove burdensome, costly, unnecessary amendments while maintaining […]

Management of Change & Pre-Startup Safety Review (Part 3)

September 18th, 2018

In Part 1 of this series, we examined the purpose of Management of Change and Pre-Startup Safety Review (MOC/PSSR) and how to determine when it is required. In Part 2 of the series, we reviewed the specific requirements of MOC/PSSR. While it may feel like a daunting task, we will now review how to implement Management of […]

Management of Change & Pre-Startup Safety Review (Part 2)

September 4th, 2018

In Part 1 of this series, we examined the purpose of Management of Change and Pre-Startup Safety Review (MOC/PSSR) and how to determine when it is required. We will now review the specific requirements of MOC/PSSR. RMP/PSM/CalARP regulations are very similar on the prescriptive requirements for both MOC and PSSR. For simplicity, we will look […]

Management of Change & Pre-Startup Safety Review (Part 1)

August 21st, 2018

When I first got into Process Safety Management, Peter Thomas advised me, “If you want to be an expert in anything, be an expert in Management of Change and Pre-Startup Safety Review.” He then added that if you understand MOC/PSSR requirements, you will understand how every other element is affected by a process change. Now […]