RMP/PSM Services
HAZOP/LOPA Facilitation
Nebula Safety & Environmental provides HAZOP/LOPA facilitation services for hazard identification. This includes PHA planning, organization, implementation, and follow-through efforts all aimed to optimize the process. Additional PHA risk assessment methodologies include:
What-If
Safety Integrity Level (SIL) Analysis
Failure Modes Effects Analysis (FMEA)
Hazard Identification (HAZID)
Inherently Safer Design (ISD)
Dust Hazard Analysis (DHA)
BowTie Analysis Support
Quantitative Risk Evaluation
Nebula Safety & Environmental assists facilities by using quantitative methods to further assess potential consequences and risk. Analyses includes:
release rate
Vapor/Liquid releases
Vapor Flashing
Liquid pooling dynamics and evaporation
dense gas dispersion
Safe venting
Monitoring and emergency response
Human vulnerability to toxics
flash fires
Ignition probability
Human vulnerability
pool fires
Burning pool dynamics
Ignition probability
Heat Radiation
vapor cloud explosions (vpes)
Jet dynamics
Flare heat radiation
Probabilistic modeling
jet fires
Jet dynamics
Flare heat radiation
Probabilistic modeling
boiling liquid expanding vapor explosions (bleve)
Fireball dynamics
Heat radiation
Human vulnerability
Nebula Safety & Environmental also conducts comprehensive Facility Siting Studies (API 752 and API 753) and Quantitative Risk Assessments (QRAs).
Process Safety Program Development
Nebula Safety & Environmental assists in building or refreshing PSM programs and systems. Existing PSM programs are reviewed for effectiveness and gap assessments are conducted to assure compliance with present or future regulations.
Operating Procedures Development
Nebula Safety & Environmental works directly with facility personnel and unit operators to develop concise step-by-step OSHA compliant operating procedures including Safe Work Practices (e.g., LOTO, Hot Work, Confined Space, Temporary Exclusion Zones, etc.). Operating procedures and practices are reviewed for clarity and Human Factors.
Incident Investigations with Root Cause Analysis
Nebula Safety & Environmental provides tools, forms, and works directly with facilities to develop a regulatory compliant Incident Investigation policy in addition to leading Incident Investigations. Methodologies include:
Taproot
Cause Map
Why Tree
Fishbone
Nebula Safety & Environmental also assists with incident investigation follow-up, including action item completion and root cause trending.
RMP Submittals
Nebula Safety & Environmental provides support for regulatory compliant EPA Risk Management plans, OSHA Process Safety Management plans, and various statewide chemical process safety plans (CalARP, TCPA, CAPP, WISHA). All of our process safety plans and submittals are coordinated with the locally mandated Administering Authority (AA) to ensure that all auditable regulatory requirements are achieved.
Dispersion Modeling & Offsite Consequence Analysis (OCA)
Nebula Safety & Environmental utilizes EPA approved software (e.g., RMP*Comp, ALOHA, SCREEN3, & SLAB) to identify the area of impact for both worst-case and alternate case scenarios.
Regulatory Support
Compliance Audits
Maximum Intended Inventory Calculations
Emergency Action Plan / Emergency Response Plan
Flare Analysis Study
Relief Valve Calculations
Regulatory interface to provide support for PSM/RMP related citations
Nebula Safety & Environmental provides support responding to regulatory citations and representation interfacing with regulatory bodies.
RMP/PSM Program development
Nebula Safety & Environmental provides RMP/PSM Program Development services to help ensure compliance with the regulations. Nebula Safety can also help track anniversary dates and provide maintenance support.
PSM/RMP & State Specific Applicability Assessments
RMP/PSM Program Development (Program I/II/III)
State Specific Program Development – Nevada Chemical Accident Prevention Program (CAPP), New Jersey Department of Environmental Protection (NJDEP) Toxic Catastrophe Prevention Act (TCPA), Delaware’s Extremely Hazardous Substances Risk Management Act (EHS), Washington Industrial Safety and Health Act of 1973 (WISHA), California CalARP / CalOSHA regulations.
Training
Training on PSM topics including but not limited to the following:
HAZOP/LOPA/FMEA
EPA RMP/OSHA PSM Program Elements & Maintenance
Process Safety Management Culture
Compliance Audit Training
Quantitative Modeling (i.e., dispersion or fire modeling)
Process Safety Management Training
Teaches regulatory requirements for OSHA PSM and EPA RMP. Provides strategies for improved management of process safety. Advantages of the Nebula Course:
Taught by an instructor with a diverse background in process safety, who has worked in the field across multiple industries, not a lifelong consultant!
Content is tailored for the worksite, depending on the type of operations and the EPA RMP Program Level (1, 2, 3, or 4 for some California Operations)
Training includes an interactive learning module highlighting Human Factors and how they can contribute to incidents
Strategies are shared to promote worker engagement, strengthen the culture, and improve process safety performance
Process Safety Culture Assessment and Improvement
Nebula Safety & Environmental conducts PSM culture assessments and partners with companies to embed work practices that benefit the culture. Techniques include:
Targeted supervisor PSM leadership coaching
Industry specific external events learning and application
Worker acknowledgement and encouragement
California Services
California State Requirements: CalARP / CalOSHA / Contra Costa County ISO
Latent Conditions Checklist
Damage Mechanism Review (DMR)
Hierarchy of Controls Analysis (HCA)
Safeguard Protection Analysis (SPA)
Management of Organizational Change (MOOC)
Security Vulnerability Assessment (SVA)
Inherently Safer Systems Analysis (ISSA)
Facility Siting Study
Human Factors Study
Process Safety Cultural Assessment (PSCA)
CalARP Submittal
CUPA regulatory support
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