Risk Management Plans: Common

Deficiencies

Amy M. Reed, PE and Laura I. Brewer

May 2015

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EPA RMP Program & EligibilityOn June 20,1996, the EPA issued the Accidental Release Prevention Requirements or Risk Management Plan (RMP) into law. The purpose is to establish management systems for chemicals which have the potential to effect public health and the environment and to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

The RMP rule (40 CFR Part 68) applies to stationary sources (facilities) with processes that contain more that the threshold quantity of a regulated substance.

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RMP Program Levels

Level 1• No history of offsite accidents• No public receptors• Emergency response coordinated with local emergency organizations

Level 2• Not eligible for Program Level 1 or 3

Level 3• Subject to OSHA PSM

Wrong program level determination

between Program 2 and 3 facilities in

OSHA and non-OSHA delegated states

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RMP Program Content

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Hazard Assessment

Prevention Program

Emergency Response

What can we do better?

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Management System Roles

► Organizational chart does not address RMP elements.

► Failure to document individuals responsible for implementing each requirement of the risk management program.

► Failure to define the lines of authority through an organization chart.

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RMP Org Chart Example

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Hazard Assessment► Incorrect Modeling Input for Worst Case &

Alternative.• Incorrect use of passive mitigation• Rural versus Urban

► Alternative Scenario Evaluations (Look at more than one!)

► Missing Supporting Documentation. • Population data• Modeling output/calculations

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Process Safety Information

#

1. MSDS

5. Documentation on codes & standards

2. Maximum Intended Inventory

3. Safe upper/lower limits

4. Block flow diagrams and P&IDs

Check for Missing PSI Components

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Hazard Review/Process Hazard Analysis

► Revalidate at least every 5 years.

► At least every 3 times, EPA recommends completely redoing the PHA or Hazard Review versus a revalidation.

► Maintain the Hazard Review/PHA for the life of the process.

► Document response to action items.

► Ensure review includes external elements such as tornadoes, hurricanes, and/or earthquakes.

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Operating Procedures

Operating procedures

must include consequences of

deviation and the steps to

avoid the consequences

of deviation.

• Review operating procedures annually• Make sure operating procedures are up to date

Each operator is to be trained on SOP’s,

understand and follow them at all times, and

suggest updates or improvements.

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Mechanical Integrity► If preventative maintenance schedule does not follow manufacturer

recommendations or design/codes/standards, document the explanation of why and how this conforms with good engineering practices.

► Historical inspection results should be reviewed to determine inspection frequencies or equipment replacement.

► Document of the results of the inspection should clearly identify if the equipment passed, failed, or requires corrective action.

► If equipment inspection shows a deficiency, document how process will be operated safely in interim until repaired.

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Contractor Safety (Program 3)► No program in place or the program simply

regurgitates the regulations.

► Communicate with contractor to make sure they are trained on your PSI, emergency response, and safe work practices associated the covered process.

► Audit the contractor while they are

working onsite to ensure they are

following safe practices.

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Training Requirements► No description of training or testing methods.

► No documentation of initial or 3-year refresher training.

► Documentation of training on operating AND maintenance procedures should be maintained.

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Employee Participation (Program 3)► Failure to develop a written plan of action for

employee participation.

► Failure to consult with employees regarding training.

► Include in hazard reviews/PHA, O&M procedures.

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Management of Change (Program 3)► Replacement in Kind versus Change

► Have affected personnel been informed and trained in the change?

► Do O&M procedures require an update because

of the change?• Have personnel been trained?

► Is the PHA, OCA, or RMP applicability impacted

by the change?• Was the hazard assessment updated?

► Does the PSI need to be updated as a result

of the change?• Has a PSSR been performed?

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Compliance Audits► Not completed every 3 years.

► Cannot locate the last two compliance audits.

► Incomplete resolution of the prior audit. Document who is responsible for responding to deficiencies, how deficiencies were resolved, and when deficiencies were resolved.

► Vague audits. Audit checklist needs to have more than “yes/no” answers, document evidence of compliance.

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Incident Investigations

► Must be initiated within 48 hours.

► Includes incidents which have or could reasonably have resulted in a catastrophic release.• If passive or mitigative safeguards prevented the release

this could reasonably have resulted in a catastrophic release incident and requires an incident investigation

• If incident is listed as an alternative release scenario, consider conducting an incident investigation.

► Must review findings with affected personnel and contractors whose jobs tasks are relevant to the finding or recommendation.

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Emergency Response

► Responding versus non-responding facilities.• Non-responding facility develops an emergency action

plan which addresses: “Responses to incidental releases of hazardous substances

where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel”, or “Response to releases of hazardous substances where there is no potential safety or health hazard” and relies on Local, County, or State Emergency response crews for all other response.

Exempt from HAZWOPER training. Steps to notify emergency responders there is a need for

response, and Emergency evacuation procedures.

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Updating, Correcting, or Resubmitting the RMP

Within 6 Months Every 5 Years

Requires revised PHA/Hazard Review

Requires revised OCA

Alters the program level of covered process.

Update and Resubmittal required

EPA Central Data Exchange requires

certifier to maintain login and password; Stringent protocols used to protect

CDX account

Accidental Release

Within 1 Months

Change in Facility Emergency Contact

No longer subject to progam

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Questions