WARNING
Compliance Deadline Approaching
Overview
Most of us are aware of the Occupational Safety and Health Administration’s (OSHA’s) requirements for a Process Safety Management (PSM) program if listed highly hazardous chemicals are on site above OSHA listed thresholds (e.g., flammable liquids, ammonia, chlorine, propane, etc.). But did you know that the USEPA has related regulations (Risk Management Plan, RMP), and their deadline for compliance, and submittal of program elements to the USEPA, is approaching (June 21, 1999).
Background
As a result of historical catastrophic events, OSHA issued regulations under Process Safety Management (PSM) to protect on-site employees, through the prevention of unplanned release of hazardous materials, from these disasters. The required elements of this standard, most of which have had PSM compliance deadlines in 1992, are the following:
1. Employee Participation; Paragraph (c);
2. Process Safety Information (PSI); Paragraph (d);
3. Process Hazard Analysis (PHA); Paragraph (e);
4. Operating Procedures; Paragraph (f);
5. Training Requirements; Paragraph (g);
6. Contractor Provision; Paragraph (h);
7. Pre-Startup Safety Review; Paragraph (i);
8. Mechanical Integrity; Paragraph (j);
9. Hot Work; Paragraph (k);
10. Management of Change; Paragraph (l);
11. Incident Investigation; Paragraph (m);
12. Emergency Planning and Response; Paragraph (n);
13. Compliance Audits; Paragraph (o); and
14. Trade Secret Provisions; Paragraph (o)
OSHA vs. USEPA Requirements
USEPA’s RMP regulations stresses off-site consequences as well as on-site prevention measures. There are some other notable differences in the 2 standards. They are, as follows:
OSHA’ PSM has exempted some operations from the PSM standard (e.g., flammables fuels used for process or comfort heating; retail or unoccupied spaces; and "storage only" facilities); USEPA’ RMP does not exempt these type facilities from compliance requirements.
OSHA’s PSM does not require any agency submittals to demonstrate compliance (you must only be ready if OSHA inspector comes); USEPA’s RMP requires submittal of site’s RMP Program Plan to the USEPA by June 21, 1999.
OSHA’s PSM has no program levels which are based on severity; USEPA’s RMP has three distinct program levels (see attached diagram).
OSHA’s PSM requires no modeling; USEPA’s RMP requires modeling of off-site consequence (results may impact what program level site is in).
What You Can Do
If your site has RMP listed chemicals:
Compare your on-site chemical inventory to USEPA RMP listed chemical thresholds (in pounds) to determine if you have amounts on-site above the listed thresholds;
Start to collect, tabulate, and document accident history related to this chemical and the "covered process;"
Conduct off-site consequence analyses using approved USEPA models (note: we can help, call John Wiemhoff of JRW Environmental at (847) 705 7781);
Determine what program level your site is in (Program 1, 2, or 3);
Prepare RMP documentation consistent with your program level (1, 2 or 3);
Submit your RMP to USEPA by June 21, 1999 deadline.
If you have clients that may be affected by this standard:
As a service to your client, make them aware of this standard, and its pending June 21, 1999 deadline;
Point out the difference between this RMP standard and OSHA’s PSM (as your clients may be confused thinking they are compliant now, e.g., PSM only);
Call JRW Environmental Consulting for further guidance or consulting support; we can serve as your subcontractor; call John Wiemhoff at (847) 705 7781.
COMPARISON OF USEPA’s RISK MANAGEMENT PLAN (RMP) PROGRAM LEVEL REQUIREMENTS |
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| Program 1 | Program 2 |
Program 3 |
| Worst-case release analysis | Worst-case release analysis | Worst-case release analysis |
| Alternative release analysis | Alternative release analysis | |
| 5-year accident history | 5-year accident history | 5-year accident history |
| Document management system | Document management system | |
Prevention Program |
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| Certify no additional prevention steps needed | Safety Information | Process Safety Information |
| Hazard Review | Process Hazard Analysis. | |
| Operating Procedures, | Operating Procedures | |
| Training | Training | |
| Maintenance | Mechanical Integrity | |
| Incident Investigation | Incident Investigation | |
| Compliance Audit | Compliance Audit | |
| Management of Change | ||
| Pre-Startup Review | ||
| Contractors | ||
| Employee Participation | ||
| Hot Work Permits | ||
Emergency Response Program |
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| Coordinate with local Responders |
Develop plan and program and coordinate with local responders | Develop plan and program and Coordinate with local responders |
Submit One Risk Management Plan for All Covered Processes |
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