The U.S. Occupational Safety and Health Administration's (OSHA) process safety management (PSM) standard set requirements for the management of hazards associated with processes that uses highly hazardous chemicals (HHC) – e.g., chemicals that are toxic, reactive, flammable or explosives (Appendix A of the standard contain the complete list of HHC's). The PSM standards are set for oil refineries and chemical plants. As compared to a refinery, an upstream oil separation process is less complex but recent changes and advancements in oil production as well as separation techniques made process safety a critical component for safe operation of production facilities and gas plants.

This paper proposes a new methodology for ensuring mechanical integrity of equipment - an important element of OSHA 1910.119. Proper documentation of relief system design and design basis is a major step in ensuring mechanical integrity. A key problem in relief device documentation is that the relief device datasheet does not include all of the overpressure scenarios considered in the original device specification. This paper proposes a basic change in the way relief systems are documented - a requirement in order to comply with OSHA 1910.119 and thereby describes a new methodology and a change in documentation to meet OSHA requirements and other industry standards (such as API 520/521, API-RP 75, 14J).

The information presented below is intended to help operators better understand the applicable requirements for production facilities and gas plants, and to develop a plan to meet the industry standards. It is also intended that the information presented below will help in proper documentation and thereby enable a faster response in case of an emergency.

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