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Mercer clarifies PHMSA and PSM boundaries with 2018 AIChE Whitepaper

DEC 2020 UPDATE
PHMSA Publishes FAQs
Midstream processing facilities under PHMSA jurisdiction should pay close attention to the proposed guidance document issued November 4, 2020. View our article on the PHMSA FAQs.

Jurisdictional Boundaries in Midstream

Where is the Line?

Account Director Lauren Mercer presented her whitepaper “Jurisdictional Boundaries in Midstream: Where is the Line?” at the 2018 AIChE Spring Meeting in Orlando, Florida. Mercer has a skill for taking complex and nuanced topics and making them manageable and consumable for the audience. The AIChE committee chose to record her presentation, and it will be made available in the archived AIChE meeting database, available to AIChE members and conference attendees.

Author: Lauren Mercer
Account Director

Paper Abstract

Where is the Line?

This paper discusses the gray area between OSHA and DOT jurisdiction, including coverage of terminal operations, railcars/trucks, and underground storage applicability. The nuances of PSM applicability, including interconnectivity and colocation, hydrocarbon used as a fuel, atmospheric tanks, and safety systems will be presented.

Furthermore, this paper will provide a history of jurisdictional boundary and PSM applicability cases/interpretations and will present examples of determining PSM jurisdiction and applicability. The intent is to pull all aspects of each regulations together in a single location to be used as a reference when evaluating the jurisdictional boundaries at a midstream facility.

Download Whitepaper

Fill in the form below to access the full whitepaper

Presentation Slides

Download the PowerPoint Show of Mercer's presentation at the 2018 AIChE Spring Meeting

Presentation Handout

Download the a Quick View Handout

Relief Systems, Webinar

Relief Devices, DOT, and OSHA: Insight for Pressure Relief Systems Engineers [Webinar]

Is your facility under the OSHA PSM Standard or the DOT PHMSA regulations? Are you confused by fuzzy jurisdictional boundaries? Take this webinar.

In this 60-minute sponsored webinar, hear Provenance Consulting tackle an issue that causes confusion for many oil and gas industry professionals: The OSHA PSM Standard and the DOT PHMSA regulations and which apply to their relief devices. Join in to examine the unclear boundary between one jurisdiction and the other and how this is a source of consternation for pressure relief systems engineers.

What is the impact on your pressure relief systems design? Which requirements are the same across both agencies? Which are different? Tune in to gain insight and guidance.

Take a look at your agenda:

  • An overview of the DOT PHMSA and its regulations
  • What you need to know about OSHA and the PSM standard
  • Understanding jurisdictional boundaries and the contentious nature between OSHA and DOT
  • What’s similar and what’s different and the impact on your pressure relief systems design and related process engineering activities

Learn more about our Relief Systems Services

Presenter

Justin Phillips, P.E.

Justin Phillips has over eight years of onshore and offshore oil & gas process engineering and project execution experience. His technical experience includes process design with specialty in flare and relief systems.

Justin is the Relief Systems Line of Service Manager at Provenance Consulting, LLC. He holds a B.S. in Chemical Engineering from Texas A&M University in College Station, Texas and is a Licensed Professional Engineer in the State of Texas.

News

2018 #AIChESpring Meeting & Global Congress on Process Safety

Find Provenance Consulting

at the #AIChESpring Meeting & #GCPS

We are thrilled to be again participating in AIChE’s 14th Global Congress on Process Safety in Orlando, Florida April 23-25th, 2018. The event features a three-day program of technical papers and workshops on topics such as: Management Systems, Big Data Analytics, Industry 4.0, changes to Industry standards, HAZOP best practices, Improving Safety Culture, and Technology.Read more

Process Safety Management, Webinar

PSM Mindsets for Everyday Use [Webinar]

Do you and your employees have a PSM mindset? Learn more.

In this Provenance Consulting sponsored webinar, take a big picture look at PSM while gaining insight into ways to improve your PSM approach and engage employees in your efforts. You’ll consider how OSHA PSM is complicated, but the intent behind it is surprisingly simple and direct. Then, you’ll unpack the five PSM mindsets that encompass the heart of the PSM regulation. You’ll view the 14 elements through a case study and see how to connect the mindsets and elements to your work tasks. In addition, you’ll be reminded how important your role in PSM is and take away specific actions that will help you take your safety to the next level.

Take a look at your agenda:

  • Understanding the five PSM mindsets
  • What success looks like for each mindset and OSHA’s 14 PSM elements
  • Growing a process safety culture in your facility
  • Steps to individual and corporate improvement within each mindset

Learn more about our Training Services

Presenter

Sarah McDuffee

Sarah McDuffee joined Provenance Consulting in 2015 as Training Program Coordinator, creating internal and external training courses for industry clients on various Process Safety Management topics. Her background includes 19 years of experience in the refining/chemical industry. She has a B.S. in Chemical Engineering from Montana State University.  Her 11 years with a major refining company included project design, process unit support and distillation consulting roles.

She completed her Masters in Adult Education and Training with Colorado State University in 2011 while working for Northern Oklahoma College as an engineering instructor for 5 years. During that time, Sarah also served as Program Director for the Process Technology program for four years, partnering with industry on curriculum, recruiting and placement.

Relief Systems, Webinar

Everything You Wanted to Know About Relief Systems but Were Too Afraid to Ask

Have you ever had a “dumb” question about pressure relief systems that you were too afraid to ask? Have no fear. Get the answer here.

Provenance Consulting is ready to answer any question you have about pressure relief systems. Submit your most burning question anonymously in advance and get the answer during this interactive, 60-minute webinar. Designed for technicians, engineers, managers and other professionals, this three-part webinar is filed with straight-forward information to help you better understand basic, intermediate and complex pressure relief system problems and situations.

Don’t be shy. That question you’re too afraid to ask may be the exact same question others have. Join us.

Learn more about our Relief Systems Services

Presenter

Justin Phillips, P.E.

Justin Phillips has over eight years of onshore and offshore oil & gas process engineering and project execution experience. His technical experience includes process design with specialty in flare and relief systems.

Justin is the Relief Systems Line of Service Manager at Provenance Consulting, LLC. He holds a B.S. in Chemical Engineering from Texas A&M University in College Station, Texas and is a Licensed Professional Engineer in the State of Texas.