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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue, Suite 900
Seattle, WA 981 01 -31 40
March 2010
U.S. EPA-Region 10
Risk Management Program Training
HAMMER Training Center
Richland, Washington
Welcome RMP Facilities:
We appreciate your investment of time and effort to attend this training. Our objective is
to inform our facilities of changes in registration protocols and to familiarize you with the
tools and requirements of the Risk Management Program.
In case you have further questions regarding the program please refer to the list of
resources below.
Best Regards,
Javier Morales
EPA Region 10
RMP 112r Coordinator
Emergency Response Unit
Office of Environmental Cleanup
(206)553-1255
morales.javier@epa.gov
Contacts for further information:
Region 10 RMP website:
http://yosemite.epa.gov/R10/airpage.nsf/Enforcement/rmp
EPA Headquarters website:
http://www.epa.gov/emergencies/content/rmp/index.htm
Help line: (800) 424-9346
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Region 10 Risk Management Training Manual EPA 910-K-10-001 March 2010
Risk Management Program Training Manual
Risk Management Plan 1
Program Elements 1
Management System 6
Five Year Updates and New Reporting Tools for 2010 11
Hazard Assessment 20
An analysis of the potential offsite consequences of accidental releases from RMP
covered facilities 20
RMP*Comp 21
LandViewฎ 6 and MARPLOT 22-23
ALOHA 24
Prevention Program 31
Process Safety Information 31
Process Hazard Analysis 37
Operating Procedures 47
Training 53
Employee Participation 61
Mechanical Integrity 64
Management of Change/ Pre-startup Safety Review 69
Compliance Audits 75
Hot Work Permit 80
Contractors 82
Incident Investigations 86
Emergency Response 92
Appendix 98
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RMP Program Elements
Program 1
Worse-case release
analysis
5-year accident history
Certify no additional
prevention steps needed
Coordinate with local
responders
Program 2
Worse-case release analysis
Alternative release analysis
5-year accident history
Document management
system
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigations
Compliance Audit
Develop plan and program
(if applicable) and coordinate
with local responders
Program 3
Worse-case release analysis
Alternative release analysis
5-year accident history
Document management
system
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigations
Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
Develop plan and program
(if applicable) and coordinate
with local responders
Submit one Risk Management Plan for All Covered Processes
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R10 Risk Management Training Manual
EPA 910-K-10-001
March 2010
Risk Management Program
Training
March 9-11,2010
HAMMER Facility
Richland, Washington
Training Objectives
Smoke billows from heavily damaged Formosa
Plastics plant following April 23 explosion. Photo:
Kevin German/The State Journal-Register. (CSB)
Understand the mission
of the Risk Management
Program and your
facility's safety culture
Understand common
deficiencies identified
from inspections
Understand the elements
required under the Risk
Management Program
Purpose of Risk Management Program
Prevent or minimize
the consequences of
catastrophic releases
of toxic, reactive,
flammable, or
explosive chemicals
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R10 Risk Management Training Manual
EPA 910-K-10-001 March 2010
Importance of Safety Culture
March 2005, Texas City, Texas oil
refinery explosion.
J The UK Health & Safety
Executive defines safely
culture as "... the product
of the individual and
group values, attitudes,
competencies and patterns
of behavior that determine
the commitment to, and
the style and proficiency
of, an organization's health
and safely programs."
Program Eligibility
n Stationary Source in
a Single Process
n Listed of Regulated
Substance
n Threshold Quantities
63 Flammables
77 Toxic
Substances
List of Lists at: http://vosemite.epa.gov/oswer/lol.nsf/homepage
Program Level
Program 1
No history of offsite accidents
No public receptors
ER coordinated w/ local emergency organizations
Industries subject to OSHA Process Safety Management
Complex processes -NH3 refrigeration, refineries, pulp &
paper mills, fertilizer manufactures, industrial gas
manufacturing, Water Treatment Plants/Wastewater
Treatment Plants
Program 2
Not eligible for Program 1 or 3
Bulk storage and distribution of chemicals, fertilizer
wholesalers, frozen and dehydrated food manufactures
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R10 Risk Management Training Manual
EPA 910-K-10-001
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Program Universe
Region 10 -479 covered facilities
31
nwA
DOR
ID
AK
Program Universe
400 -I 359
350 -
300 -
250 -
200 -
150 -
100 -
50 -
0
# of Hazardous Chemical Facilities
74
24
15
12
Exemptions to Program
Farmers using ammonia fertilizer
Flammable substances used as fuel or held for
sale as a fuel at a retail facility
Chemicals in transportation, including storage
incident to transportation
Naturally occurring hydrocarbon mixtures prior
to entering a processing plant
Laboratory chemicals
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General Duty Clause
Section 112(r)(1)-
"General duty to identify,
prevent the release of
extremely hazardous
substances, and minimize
consequences, if a
release were to occur."
Content of Program
Hazard Assessment - The potential worst-case
and more probable accidental release
scenario. 5 yr accident history.
Prevention Program - Safety information,
hazard review/analysis, operating procedures,
mechanical integrity/maintenance, employee
training.
Emergency Response - Emergency response
plan or program, employee training,
procedures for informing the public and local
responders.
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
Management System
Common Deficiencies:
A company organizational chart that does not address the RMP elements
Failure to document other persons responsible for implementing individual
requirements of the risk management program and
Failure to define the lines of authority through an organization chart or similar
document
REQUIREMENTS
If you have a Program 2 or Program 3 process the management system provision
requires you to:
Develop a management system to oversee the implementation of the risk
management program elements;
Designate a qualified person or position with the overall responsibility for the
development, implementation, and integration of the risk management program
elements; and
Document the names of people or positions and define the lines of authority
through an organizational chart or other similar document, if you assign
responsibility for implementing individual requirements of the risk management
program to people or positions other than the person or position with overall
responsibility for the risk management program.
HOW TO MEET THE MANAGEMENT SYSTEM REQUIREMENTS
Sources covered by this rule are diverse, so you are in the best position to decide how to
appropriately implement the risk management program elements at your facility.
Therefore, the rule provides considerable flexibility in complying with its program
requirements.
WHAT DOES THIS MEAN FOR ME AS A SMALL FACILITY?
Identification of a qualified individual or position with overall responsibility may be all you
need to do if the person or position named directly oversees the employees operating
and maintaining the processes. You must define the lines of authority with an
organizational chart or similar document only if you choose to assign responsibility for
specific elements of the risk management program to persons or positions other than the
person with overall responsibility. For a small facility, with few employees, it is likely that
you will meet the requirements of this provision by identifying the one person or position
with the overall responsibility of implementing the risk management program elements. If
this is the case, you need not develop an organizational chart.
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WHAT DOES THIS MEAN FOR ME AS A MEDIUM OR LARGE FACILITY?
As a medium or large facility you may have more personnel turnover than smaller sites.
For this reason, it may make more sense at your facility to identify a position, rather than
the name of the specific person, with overall responsibility for the risk management
program elements.
As a relatively large or complex facility, you may choose to identify several people or
positions to supervise the implementation of the various elements of the program;
therefore, you must define the lines of authority through an organizational chart or similar
document.
Defining the lines of authority and roles and responsibilities of staff that oversee the risk
management program elements will help to:
Ensure effective communication about process changes between divisions;
Clarify the roles and responsibilities related to process safety issues at your
facility;
Avoid problems or conflicts among the various people responsible for
implementing elements of the risk management program;
Avoid confusion and allow those responsible for implementation to work together
as a team; and
Ensure that the program elements are integrated into an ongoing approach to
identifying hazards and managing risks.
Remember that all of the positions you identify in your documentation will report their
progress to the person with overall responsibility for the program. However, nothing in
the risk management program rule prohibits you from satisfying the management
provision by assigning process safety committees with management responsibility,
provided that an organizational chart or similar document identifies the names or
positions and lines of authority.
MANAGEMENT DOCUMENTATION SAMPLE
Risk Management Program Element
Overall responsibility - RMProgam
Manager
Hazard Review
Safety Information
Operating Procedures
Training
Maintenance
Incident Investigation
Emergency Planning and Response
24-Hour Emergency Contact
Compliance Safety Audits
RMP Plan Updates (5-year and
changes)
Responsible Employee(s)
(Specific names or positions)
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R10 Risk Management Training Manual
EPA 910-K-10-001 March 2010
MANAGEMENT RESPONSIBILITIES FOR RMP/PSM - Program 3
Elements of RMP/PSM
1) Management System:
Responsible Parties
A) President/CEO/Operations Manager, etc - Overall Responsibility for the
development, implementation and integration of the risk management program
elements.
Each Section Below Reports to the above (President/CEO/Operations Manager, etc.)
2) Employee
Participation
3) Process Safety
Information:
4) Process Hazard
Analysis:
5) Operating
Procedures:
6) Lockout/Tagout:
7) Site Security:
8) Line Opening/Process
Equipment:
9) Training:
10) Mechanical
Integrity:
11) Preventative
Maintenance:
12) Management of
Change ^
13)Pre-Startup Safety
Review ^
14) Compliance Audits:
15) Incident
Investigations
: 16) Hot Work, Permits
17) Contractors:
18) Emergency Action
Program ^
19) Trade Secrets
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
D) Training Coordinator ,^r
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Refrigeration Engineers D) Safety Mgr. ^^^. ^
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Safety Mgr.
A) President/CEO B) Security Mgr. C) Maintenance and Refrigeration Mgr. D)
Plant Managers
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
D) Training Coordinator
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman , C) Safety
Mgr. ^
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Plant
Managers D) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Safety Mgr
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Purchasing Agent
A) President/CEO B) Safety Mgr.
Not applicable
Date Last Revised:
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R10 Risk Management Training Manual
EPA 910-K-10-001 March 2010
Management System
Required for Program Level 2 & 3 facilities
Must be documented
Must describe who is ultimately in-charge and
those authorized to make decisions and
implement the plan
Overall responsibility
Assign a qualified
person or position
that has the overall
responsibility for the
development,
implementation, and
integration of the
Risk Management
Program elements
If you are a small facility
One individual may be
adequate to oversee
the:
Development
Implementation
Integration of the RMP
elements
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If you are a large facility
, Document all
individuals
responsible for
implementing
individual RMP
requirements and
defined the lines of
authority through
an organization
chart or similar
document
Identify the lines of authority
Example: Training -shared responsibility
Maintenance Manager
Engineering Foreman
Safety Mgr.
Training Coordinator
Group Reports to Plant Manager
Management
Common Deficiencies
A company organizational chart that does not
address the RMP elements
Failure to document other persons
responsible for implementing individual
requirements of the risk management
program
Failure to define the lines of authority through
an organization chart or similar document
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Five Year Updates and New Reporting Tools
Five-Year Updates
All facilities with a current Risk Management Plan (RMP) must completely update
all nine sections of their RMP at least once every 5 years from the initial
submission or most recent update (even if no changes occur). [40 CFR
ง68.190(b)(1) of the Clean Air Act].
Your five-year anniversary date is listed in the notification letter which was sent to
you after you submitted your last RMP. You can also find your anniversary date
in the Registration Section of the hard copy of your RMP and online in the
Registration Section of RMP*WebRC (a web based tool for minor
corrections/updates).
RMP*eSubmit: New web-based tool designed for complete RMP
submissions
You will use RMP*eSubmit, an online reporting tool which simplifies the
submission process. EPA uses industry-standard technology, including
encryption used by most commercial banks, as well as stringent user ID and
password protocols to protect your information.
You will be able to access your entire RMP online at anytime (Fig. 1). In addition
to updating your facility's RMP at least every five years or when other specified
update circumstances occur, RMP*eSubmit allows you to perform other recurring
activities to ensure that your risk management program is current. These
activities include, among other things, providing employee refresher training,
performing compliance audits, and updating your safety information, hazard
review (or process hazards analysis), operating procedures, and offsite
consequence analysis.
Preparer
1. RMP Entered
4. Update
Certifier
2. Notification and
Copy of Record
3. Approval and
Submission
5. Confirmation
Figure 1:
How the RMP
Submission
Process Will
Work
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Why has EPA developed RMP*eSubmit?
The web-based RMP*eSubmit tool offers many advantages (Fig.2), including, but
not limited to:
Online (24/7) access to your RMP,
Ability to review, submit, correct, update and validate all sections of your
RMP at a secure website (http://www.epa.gov/cdx/, CDX),
A one-time only, mailed in, Electronic Signature Agreement with all
subsequent transactions online via the CDX website, and
The ability of a facility's certifier to designate a "Preparer" who will be able
to prepare, correct and/or update one or more RMPs and transmit them to
the facility for review and approval. Note that only the facility's certifying
official can submit the RMP(s) to EPA
EPA's Firewall
n^r^
What about the
certification letter?
Replaced by a one-
time Electronic
Signature Agreement
RMP
Database
Figure 2:
RMP*eSubmit -
RMP Submission
via the Internet
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Updates & Required Corrections
Risk Management Plan
Updates [ง68.190]
Changes that typically require updating information in more than one
section of the RMP
Change That Occurs
No changes occur
A newly regulated substance is first
listed by EPA
A regulated substance first becomes
present above its threshold quantity in: -
-a process already covered; or --a new
process
A change occurs at your facility that
requires a revised PHA or hazard review
A change occurs at or near your facility
that requires a revised offsite
consequence analysis (e.g., you
increase your inventory of a regulated
substance such that it increases the
distance to the endpoint by a factor of 2
or more, or a new public receptor is
constructed near your facility)
A change occurs that alters the Program
level that previously applied to any
covered process
Date by Which You Must Update your RMP
At least once every 5 years from its initial
submission or most recent update
Within 3 years of the date EPA listed the newly
regulated substance if your facility has more than
a threshold quantity of that substance in a
process
On or before the date the quantity of the
regulated substance exceeds the threshold in the
process
Within 6 months of the change
Within 6 months of the change
Within 6 months of the change
De-registration is a special type of "Update"
Change That Occurs
A change occurs that makes the facility
no longer subject to the requirement to
submit an RMP
Date by Which You Must De-register your RMP
Submit a de-registration letter indicating that the
RMP is no longer required to EPA within 6
months of the change
To De-register:
Submit a letter to the RMP Reporting Center within six months and include the
effective date of the de-registration (the date on which you facility was no longer
covered by Part 68). The letter should be signed by the owner or operator.
Include your RMP ID number (the 12-digit EPA ID number).
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Updates & Required Corrections
Risk Management Plan
Required Corrections [ง 68.195]
Changes are usually limited to one section of the RMP
Change That Occurs
Date by Which You Must Correct your RMP
An accidental release meeting the
reporting criteria of ง 68.42 occurs at
your facility
Add to and correct accident history information
and incident investigation data elements within
6 months of the date of the accident
Revising other RMP sections is not required
unless facility changes resulting from an accident
trigger a full update
Facility emergency contact information
changes
Correct the emergency contact information in
RMP within one month of the change
Revising other RMP elements not required). This
correction can be done via the Internet
Minor administrative change (i.e.,
correct a clerical error or supply
additional information)
Correct the information as soon as practicable
(revising other RMP elements is not required).
This correction can be done via the Internet
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RMP*eSubmit
EPA's initiative for Internet-based
RMP Submissions
The First Year
Topics
RMP*eSubmit Overview
Schedule
Publications
Registration Process
RMP Data Entry & Submission Process
Common Problems
The First Year - Region 10's Experience
EPA's initiative for web-based RMP submissions
Old System: RMP*Submit
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EPA 910-K-10-001 March 2010
EPA's initiative for web-based RMP submissions
Disadvantages of RMP*Submit
Limited validation
Facilities often lose their last submission
Heavy processing load with manual steps
Cumbersome mail back notification and resubmission cycle
New Certification Letter required for each submission
Security issue: mailing of sensitive data
EPA's initiative for web-based RMP submissions
New system: RMP*eSubmit
RMP Submission via the Internet
What about the
certification letter?
Replaced by a one-
time Electronic
Signature Agreement
EPA's initiative for web-based RMP submissions
Central Data Exchange (CDX)
EPA's secure portal for entering and retrieving information
Many other data systems currently using CDX:
> AQS, eBeaches, elUR, LEAD, NEI, NESHAFS, PMN, RCRA, SDWIS, TRI-
ME, TSCA, UCMR2, RMP*WebRC
Facilities use CDX to gain access to RMP*eSubmit
Facilities can use their existing CDX account if they have one
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R10 Risk Management Training Manual
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EPA's initiative for web-based RMP submissions
How the Electronic Signature Process Works
Facility
1. Owner/Operator
obtains Login
ID & Password
Schedule
RMP*eSubmit Activated
. March 2009
Removed RMP*Submit from website
June 2009
No longer accept submissions from RMP*Submit
January 2010
Publications
See www.epa.gov/emergencies/rmp:
A Checklist for Submitting Your Risk Management
Plan (RMP) for Chemical Accident Prevention
RMP*eSubmit User's Manual
. RMP Fact Sheet
The General Duty Clause Fact Sheet
Chemical Emergency Preparedness and Prevention in
Indian Country
Updated RMP technical guidance documents (General
guidance, industry sector guidance, OCA guidance)
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RMP*eSubmit User's Manual
RISK MANAGEMENT PLAN
RMP'eSusMiT USERS' MANUAL
Users' Manual for
RMP'eSubmit
"How To" Guide
Updated September 2O(&
Basic Steps to set up RMP'eSubmit access for a facility
CDX Registration Process
Common Problems
RMP'eSubmit User's Manual
Chapter 1 Getting Started
Certifying official sets up CDX account & registers for RMP*eSubmit
- Add Program: "Risk Management Plan (RMPESUBMIT)"
- Add Role/Program ID: "certifying official"
Certifying official completes Electronic Signature Agreement (ESA) via
online form
- ESA includes list of facilities belonging to the certifier
- Certifying official prints and signs the ESA
- Certifying official mails ESA to the RMP Reporting Center
RC validates the ESA, sets up database access & emails certifying
official an authorization code for a preparer
Preparer sets up their own CDX account
- Add Role: "preparer" (using authorization code obtained from
certifying official) "Preparer" doesn't receive the code.
Basic Steps to set up RMP'eSubmit access for a facility
RMP Data Entry
RMP'eSubmit User's Manual
Chapter 2 Entering Data (First-Time, Corrections, Resubmissions)
5. Preparer enters RMP data for facility
RMP Submission Process
RMP'eSubmit User's Manual
Chapters How to Submit Your RMP
6. Certifying official: Approval, Certification and Submittal of the RMP
Certifying Official Doesn't Submit the RMP.
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Common Problems
Step 3. Approval and Submission
Region 10 - The First Year
Five-Year Updates in R-10
All facilities must
completely update all
nine sections of their RMP
at least once every 5
years, even if no changes
occur.
Current/Registered
Facilities: 479
. 289 Updates (2009)
Late re-submissions: 41
EPA Region 10
2009 RMP Resubmissions: 5 Year Updates
X 300
o. of Facilit
1
1 2 3 4 5 6 7 8 9 10 11 12
Month
Where Do I Go For More
Information?
EPA RMP Website:
http ://www.epa .gov/emergencies/rmp
EPA Listservs:
https://lists.epa.gov/read/all forums/subscribe?name=ca
llcenter oswer
EPA Region 10 RMP Website:
. http://vosemite.epa.gov/R10/CLEANUP.NSF/sites/rmp
EPA Region 10 CEPP Newsletter
EPA Region 10 RMP Coordinator:
Javier Morales, 206-553-1255
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
Hazard Assessment
An analysis of the potential offsite consequences of accidental releases from
RMP covered facilities
If you are RMP covered facility, you are required to conduct an offsite consequence
analysis to provide information to the state, local, and federal governments and the
public about the potential consequences of an accidental chemical release. The offsite
consequence analysis consists of two elements:
A worst-case release scenario, and
Alternative release scenarios.
To simplify the analysis and ensure comparability, EPA has defined the worst-case
scenario as the release of the largest quantity of a regulated substance from a single
vessel or process line failure that results in the greatest distance to an endpoint. In broad
terms, the distance to the endpoint is the distance a toxic vapor cloud, heat from a fire,
or blast waves from an explosion will travel before dissipating to the point that serious
injuries from short-term exposures will no longer occur.
Alternative release scenarios are scenarios that are more likely to occur than the worst-
case scenario and that will reach an endpoint offsite, unless no such scenario exists.
You may use EPA's RMP Offsite Consequence Analysis Guidance (tables) to carry out
your consequence analysis. EPA's guidance is optional, and you are free to use other air
dispersion models, fire or explosion models, or computation methods provided that:
1. They are publicly or commercially available or are proprietary models that you
are willing to share with the implementing agency;
2. They are recognized by industry as applicable to current practices;
3. They are appropriate for the chemicals and conditions being modeled;
4. You use the applicable definitions of worst-case scenarios; and
5. You use the applicable parameters specified in the rule.
In addition to EPA's RMP Offsite Consequence Analysis Guidance (tables), air
dispersion/ fire or explosion models such as RMP*COMP, ALOHA and DEGADIS are
commonly used.
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
RMP*Comp
RMP*Comp is a free program you can use to complete the offsite consequence
analyses (both worst case scenarios and alternative scenarios) required under
the Risk Management Program rule. When you use RMP*Comp, you don't need
to make any calculations by hand and the program guides you through the
process of making an analysis.
The RMP*Comp program steps users through a short list of questions about the
CAA regulated chemical (such as the amount released) in the offsite
consequence analysis-both worst-case and alternative scenarios can be run.
Based on entered information, RMP*Comp estimates the distance to endpoint
according to EPA's recommended procedures. The facilities can then enter the
RMP*Comp values into their final RMP plan.
About RMP*Comp, Version 1.07:
The current version is RMP*Comp 1.07. This version was posted on October 29,
2001. It corrects bugs found in previous versions and modifies some
functionality. If you have been using an earlier version, you should Download
RMP*Comp, Version 1.07. Because the recommended RMP consequence
analysis procedures may change in the future, please check this web page
before you begin a consequence analysis to be sure that you are using the latest
version of RMP*Comp.
To download the RMP*Comp program, or to get more information
about RMP*Comp, go to the EPA Emergency Management webpage
at: http://www.epa.gov/emergencies/tools.htm
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LandViewฎ 6
For Risk Management Plan reporters who need to obtain the latitude
and longitude of their facilities.
Download from the EPA Emergency Management webpage at:
http://www.epa.gov/emergencies/tools.htm
The LandView 6 and MARPLOTฎ software were created by agencies of the U.S.
Government and are in the public domain. They can be copied, used and
distributed freely without the requirement for royalty payments or further
permissions. However, the Census Bureau cannot provide technical support for
products created by others using LandView.
The LandView database software:
Uses the Population Estimator function to calculate Census 2000
demographic and housing characteristics for user defined radii.
Creates simple thematic maps of Census 2000 data.
Allows users to browse and query the Census, EPA or USGS
databases and show the query results on the map.
Provides the capability to locate a street address or intersection on a
map based on TIGER/Lineฎ 2000 road features and address ranges.
Can automatically retrieve LandView database information for user
selected map objects.
Released January 20, 2004. LandView 6 updates the Census 2000 statistical
data as well as the Environmental Protection Agency (EPA) and U.S. Geological
Survey (USGS) databases contained in LandView 5 that was released in
November, 2002. If all you need to do is prepare EPA Risk Management Plans,
then there is no need to upgrade from LandView 5 to LandView 6.
Source: U.S. Census Bureau Geography Division
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
MARPLOT
Mapping Applications for Response, Planning, and Local
Operational Tasks
An updated version of the MARPLOT mapping program is now available. The
updated program is part of the CAMEO software suite, created for hazmat
responders and planners by OR&R in collaboration with EPA. The program is
available at no cost.
MARPLOT may be used to fulfill the requirements of 40 CFR Part 68.30
"Defining offsite impactspopulation." The application can:
Estimate (in the RMP) the population within a circle with its center at the
point of the release and a radius determined by the distance to the
endpoint defined in 68.22(a).
The population shall include residential population. The presence of
institutions (schools, hospitals, prisons), parks and recreational areas, and
major commercial, office, and industrial buildings shall be noted in the
RMP. [68.22(b)]
You can create and document maps of the worst case/alternative release
scenarios. In addition, you can document the population estimates within
the threat zones. [68.39(e)].
Working in MARPLOT'S easy-to-use CIS interface, you can switch between three
base maps: standard map files, high-resolution aerial photos, and topographical
maps. You can get population estimates inside selected areas and can
customize maps using drawing tools and an extensive symbol set.
MARPLOT 4.1.1 incorporates web-mapping services and supports the use of
shapefiles and a variety of raster formats. You'll be able to click on a location of
interest to get its elevation and an instant weather forecast, and you can work
with Landview-like population functions. As you work with the new version, the
latest U.S. Census county maps, and state and national map layers will
automatically download.
For full details and to download the free application, go to MARPLOT web-page:
http://www.epa.gov/emergencies/content/cameo/marplot.htm
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
ALOHA
Areal Locations of Hazardous Atmospheres
Part of the CAMEO suite, ALOHAฎ is an atmospheric dispersion model used for
evaluating releases of hazardous chemical vapors. ALOHA allows the user to
estimate the downwind dispersion of a chemical cloud based on the
toxicological/physical characteristics of the released chemical, atmospheric
conditions, and specific circumstances of the release. Graphical outputs include
a "cloud footprint" that can be plotted on maps with MARPLOT to display the
location of other facilities storing hazardous materials and vulnerable locations,
such as hospitals and schools.
Specific information about these locations can be extracted from CAMEO
information modules to help make decisions about the degree of hazard posed.
Key Program Features
Generates a variety of scenario-specific output, including threat zone
plots, threat at specific locations, and source strength graphs.
Calculates the rate of release for chemicals escaping from tanks,
puddles (on both land and water), and gas pipelines and predicts how
that release rate changes over time.
Models many release scenarios: toxic gas clouds, BLEVEs (Boiling
Liquid Expanding Vapor Explosions), jet fires, vapor cloud explosions,
and pool fires.
Evaluates different types of hazard (depending on the release
scenario): toxicity, flammability, thermal radiation, and overpressure.
Displays threat zones on MARPLOT maps (and on ArcView and
ArcMap with the Arc Tool extensions).
Works seamlessly with companion programs CAMEO Chemicals and
MARPLOT; it can also be used as a standalone program.
For more information, see Downloading, Installing, and Running ALOHA.
http://www.epa.gov/oem/content/cameo/aloha.htm
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R10 Risk Management Training Manual
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Hazard Assessment
Predicting Potential Impacts to the Community
Offsite Consequences Analysis
Common Inspection Deficiencies Highlighted
Agenda
Types of Scenarios
Definitions
- Required Scenarios &
Parameters
Release Mitigation
Modeling
- Offsite Impacts Receptors
- OCA Documentation
)rch2010 EPA Region 10
Types of Scenarios
Worst-case release
scenarios
- Based on conservative
assumptions
- Represent a very
severe accident that is
unlikely to occur
Alternative release
scenarios
- Based on more
realistic assumptions
- More likely to occur
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R10 Risk Management Training Manual
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Definitions
Offsite: Areas beyond the property boundary of the stationary source,
and areas within the property boundary to which the public has
routine and unrestricted access during or outside of business
hours
Worst-case Release Scenario: The release of the largest quantity of a
regulated substance from a vessel or process line failure that results
in the greatest distance to an endpoint
- Does not depend on Program Level
Alternative Release Scenario: Scenarios that are more likely to occur
than the worst case scenario and that will reach an endpoint offsite,
unless no such scenario exists
- Should consider the 5-year release history and failure scenarios identified in
the PHA or Hazard Review
Public Receptors: Public Receptors: Offsite areas such as residences,
schools, office buildings, and parks where members of the public could
be exposed
Required OCA Scenarios
Common Deficiencies
For Each Program 1 Process
- One worst-case scenario for each Program 1
process
Wo public receptors in worst-case scenario zone and
No accidents with OFF-Site consequences in last five
years
- No alternative scenarios are required
Required OCA Scenarios (cont'd)
Common Deficiencies
For All Program 2 and 3 Processes
- One worst-case scenario for all toxics
- One worst-case scenario for all flammables
- Additional worst-case scenarios if different public receptors
could be affected
Public Receptors: Offsite areas such as residences, schools,
office buildings, and parks where members of the public
could be exposed
- At least one alternative scenario for each toxic
- At least one alternative scenario for all flammables
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R10 Risk Management Training Manual
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Release Mitigation
Common Deficiencies
Activities or equipment designed to contain released substances to
minimize exposure
Passive mitigation
- Function without human, mechanical, or other energy input
- Can use in worst-case and alternative release scenario analyses if
capable of withstanding release event
- Examples include building enclosures, dikes, and blast walls
Active mitigation
- Need human, mechanical, or other energy input to function
- Can be considered only in alternative release scenario analyses, must
be capable of withstanding release event
- Examples include interlocks, shutdown systems, pressure relieving
devices, flares, emergency isolation systems, etc.
Effectiveness of Building Mitigation
for Alternative Release Scenarios
Modeling OCA Scenarios
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R10 Risk Management Training Manual
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Calculating Release Scenarios
Methods to calculate release scenarios:
- EPA
RMP *Comp - Computer software, easy to use, need basic
data parameters (volume, size of container)
EPA tables - EPA guidance documents
- Industry specific guidance
TFI [myRMP]
- Other Models - Such as /Area/ Locations of Hazardous
Atmospheres (ALOHAฎ), DEGADIS
Offsite Consequence Parameters
Common Deficiencies
' Offsite consequence analysis
must include:
- Toxics
Toxic end points
- Flammables
Overpressure, Radiant
heat, Concentration -
lower flammability limit
- Must also consider:
Wind speed, stability
class, ambient
temperature, height of
release, and topography,
Liquid or gas release
OCA Release Calculations
Common Deficiencies
Determine Distance
to Endpoint (DTEP)
- Air dispersion models
Based on Human
Health Impacts within
the area of a circle (of
radius DTEP)
- Common Models
RMP'COMP (EPA)
ALOHA
DEGADIS (TFI)
Define Off-Site Impacts
- Public Receptors
- Residential
Population Estimate
(Number)
- Institutions, . . . major
commercial, office . ..
buildings (Presence)
Most recent Census data
(LandView/Marplot) or
"other updated
information"
- Environment
National/State Parks etc.
Local U.S.G.S maps
and/or Landview
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Distance To End Points
Common Deficiencies
Wrong modeling Input for endpoint calculations
- Incorrect use of Passive Mitigation
- Incorrect use of "Rural" vs. "Urban" topography
- Hazard review information not considered for the alternative release
scenario
Defining off site impacts on population
- Did not use or misused the "circle" map when defining the off-site
impacts
Did not use most recent census data or provide "other updated
information"
- Did not identify environmental receptors within the circle
- Did not use USGS data to identify environmental receptors
Used old data for the update
- Incorrect quantities, physical locations etc.
Did not maintain the documentation for all of the calculations,
estimates, etc
- Dated, detailed documentation
The Most Common Deficiency
Documentation Missing
-Worst-case scenario ง 68.39(a)
Description of the vessel or pipeline and
substance selected as worst case, assumptions
and parameters used, and the rationale for
selection; assumptions shall include use of any
administrative controls and any passive mitigation
that were assumed to limit the quantity that could
be released. Documentation shall include the
anticipated effect of the controls and mitigation on
the release quantity and rate.
-Alternative scenario ง 68.39(b)
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R10 Risk Management Training Manual
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Review and Documentation
Common Deficiencies
Offsite consequence
analysis
- review and update the
offsite consequence
analyses at least once
every 5 years, or
- Within 6 months of any
process change that
could increase or
decrease the DTEP 2X
Five-year accident history
Common Deficiencies
An Accident is Reportable . . . if the release:
- Onsite Deaths, injuries or property damage.
- [Known] Offsite Deaths, injuries, property damage,
or environmental damage, evacuations, or sheltering-
in-place.
Requires corrections to the RMP within 6
months. {ง 68.195 Required Corrections}
Includes data required under งง 68.168, 68.170(j) [Prgm 2],
and68.175(l)[Prgm3]
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
Prevention Program
Process Safety Information
Complete and accurate written information concerning process chemicals, process
technology, and process equipment is essential to an effective process safety
management program and to a process hazards analysis. The compiled information will
be a necessary resource to a variety of users including the team that will perform the
process hazards analysis; those developing the training programs and the operating
procedures; contractors whose employees will be working with the process; those
conducting the pre-startup reviews; local emergency preparedness planners; and
insurance and enforcement officials.
The information to be compiled about the chemicals, including process intermediates,
needs to be comprehensive enough for an accurate assessment of the fire and
explosion characteristics, reactivity hazards, the safety and health hazards to workers,
and the corrosion and erosion effects on the process equipment and monitoring tools.
Current material safety data sheet (MSDS) information can be used to help meet this
requirement, which must be supplemented with process chemistry information including
runaway reaction and over pressure hazards if applicable.
Process technology information will be a part of the process safety information package
and it is expected that it will include diagrams as well as employer established criteria for
maximum inventory levels for process chemicals; limits beyond which would be
considered upset conditions; and a qualitative estimate of the consequences or results
of deviation that could occur if operating beyond the established process limits.
Employers are encouraged to use diagrams which will help users understand the
process.
A block flow diagram is used to show the major process equipment and interconnecting
process flow lines and show flow rates, stream composition, temperatures, and
pressures when necessary for clarity. The block flow diagram is a simplified diagram.
Process flow diagrams are more complex and will show all main flow streams including
valves to enhance the understanding of the process, as well as pressures and
temperatures on all feed and product lines within all major vessels, in and out of headers
and heat exchangers, and points of pressure and temperature control. Also, materials of
construction information, pump capacities and pressure heads, compressor horsepower
and vessel design pressures and temperatures are shown when necessary for clarity. In
addition, major components of control loops are usually shown along with key utilities on
process flow diagrams.
Piping and instrument diagrams (P&IDS) may be the more appropriate type of diagrams
to show some of the above details and to display the information for the piping designer
and engineering staff. The P&IDS are to be used to describe the relationships between
equipment and instrumentation as well as other relevant information that will enhance
clarity. Computer software programs which do P&IDS or other diagrams useful to the
information package, may be used to help meet this requirement.
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
The information pertaining to process equipment design must be documented. In other
words, what were the codes and standards relied on to establish good engineering
practice. These codes and standards are published by such organizations as the
American Society of Mechanical Engineers, American Petroleum Institute, American
National Standards Institute, National Fire Protection Association, American Society for
Testing and Materials, National Board of Boiler and Pressure Vessel Inspectors,
National Association of Corrosion Engineers, American Society of Exchange
Manufacturers Association, and model building code groups. In addition, various
engineering societies issue technical reports which impact process design. For example,
the American Institute of Chemical Engineers has published technical reports on topics
such as two phase flow for venting devices. This type of technically recognized report
would constitute good engineering practice.
For existing equipment designed and constructed many years ago in accordance with
the codes and standards available at that time and no longer in general use today, the
employer must document which codes and standards were used and that the design and
construction along with the testing, inspection and operation are still suitable for the
intended use. Where the process technology requires a design which departs from the
applicable codes and standards, the employer must document that the design and
construction is suitable for the intended purpose.
Source: OSHA Guidance on PSM (1910.119)
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R10 Risk Management Training Manual
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RMP PROCESS SAFETY INFORMATION Requirements
Title 40: PART 68CHEMICAL ACCIDENT PREVENTION PROVISIONS
Subpart CProgram 2 Prevention Program, ง 68.48
Subpart DProgram 3 Prevention Program, ง 68.65
Common Deficiencies:
> Missing or outdated MSDS
> Missing Maximum Intended Inventory
> Missing safer upper/lower limits
> Missing documentation on changing obsolete equipment/design or still
safe
> Missing Block Flow Diagrams
> Missing or unapproved PI&D
> Missing ventilation system design
> Missing "good engineering practices"
Purpose of process safety information:
Understand the safety-related aspects of the equipment and processes,
know what limits are placed on your operations and adopt accepted
standards and codes that apply.
Foundation for an effective prevention program.
Owner/Operator responsibility:
PROGRAM 2: Compile and maintain up-to-date safety information related
to the regulated substances, processes, and equipment.
PROGRAM 3: Complete a compilation of written process safety
information before conducting any process hazard analysis required by
the rule. The compilation of written process safety information is to enable
the owner or operator and the employees involved in operating the
process to identify and understand the hazards posed by those processes
involving regulated substances. This process safety information shall
include information pertaining to the hazards of the regulated substances
used or produced by the process, information pertaining to the technology
of the process, and information pertaining to the equipment in the process.
PROGRAM 2: PROCESS SAFETY INFORMATION REQUIREMENTS
You must compile and maintain
this safety information
You must ensure
You must update the safety
information if
Material Safety Data Sheets
Maximum intended inventory
Safe upper and lower
parameters
Equipment specifications
Codes & standards used to
design, build, and operate the
process
That the process is
designed in compliance with
recognized codes and
standards
There is a major change at
your business that makes the
safety information inaccurate
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PROGRAM 3: PROCESS SAFETY INFORMATION REQUIREMENTS
For chemicals, you must
complete information on
For process technology, you
must provide
For equipment in the
process, you must include
information on
Toxicity
Permissible exposure limits
Physical data
Reactivity
Corrosivity
Thermal & chemical stability
Hazardous effects of
inadvertent mixing of materials
that could foreseeably occur
A block flow diagram or
simplified process flow
diagram
Information on process
chemistry
Maximum intended
inventory
Chemical Safe upper &
lower limits: temperature,
pressure, flows, or
composition
An evaluation of the
consequences of deviation
Materials of construction
Piping & instrument
diagrams (P&IDs)
Electrical classification
Relief system design &
design basis
Ventilation system design
Design codes & standards
employed
Safety systems
Material and energy
balances for processes built
after June 21, 1999
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R10 Risk Management Training Manual
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Process Safety Information
Risk Management Program
Focus
o Process Safety
Information
Requirements
o Program Level
Differences
Program 2
Program 3
o Common
Deficiencies
General Requirements
o Hazard
Information of the
regulated
substance used in
the process
o Information on the
technology in the
process
o Information on the
equipment in the
process
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R10 Risk Management Training Manual
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Program 2 Requirements
Maximum
13] Intended
Inventory
MSDS
Equipment
Specifications
Safe Upper/Lower Limits Ljy ;:;
March 2010 EPA Region 10
Program 3 Requirements
Maximum
j] Intended
Inventory
MSDS
Process
Chemistry
Safe Upper/Lower Limits Consequences of Deviation
March 2010 EPA Region 10
Program 3 Requirements
Block Flow Diagram
Material of Construction
March 2010 EPA Region 10
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R10 Risk Management Training Manual
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Program 3 Requirements
Relief System Design
Electrical Classification
Material 4
Energy
Ventilation System Design Balance
Safety System
Common Deficiencies
o Missing:
MSDS
Maximum Intended
Inventory
Safer upper/lower
limits
Documentation on
existing equipment
with codes,
standards or
practices no longer
in general use.
Common Deficiencies
o Missing:
Block Flow
Diagrams
PI&D or
unapproved
Ventilation
system design
"Good
engineering
practices"
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
Process Hazard Analysis
The process hazard analysis is a thorough, orderly, systematic approach for identifying,
evaluating, and controlling the hazards of processes involving highly hazardous
chemicals. The employer must perform an initial process hazard analysis (hazard
evaluation) on all processes covered by this standard. The process hazard analysis
methodology selected must be appropriate to the complexity of the process and must
identify, evaluate, and control the hazards involved in the process.
First, employers must determine and document the priority order for conducting process
hazard analyses based on a rationale that includes such considerations as the extent of
the process hazards, the number of potentially affected employees, the age of the
process, and the operating history of the process. All initial process hazard analyses
should be conducted as soon as possible, but at a minimum, the employer must
complete no fewer than 25 percent by May 26, 1994; 50 percent by May 26, 1995; 75
percent by May 26, 1996; and all initial process hazard analyses by May 26, 1997.
Where there is only one process in a workplace, the analysis must be completed by May
26, 1994.
Process hazard analyses completed after May 26, 1987 that meet the requirements of
the PSM standard are acceptable as initial process hazard analyses. All process hazard
analyses must be updated and revalidated, based on their completion date, at least
every five years.
The employer must use one or more of the following methods, as appropriate, to
determine and evaluate the hazards of the process being analyzed:
What-if,
Checklist,
What-if/checklist,
Hazard and operability study (HAZOP),
Failure mode and effects analysis (FMEA),
Fault tree analysis, or
An appropriate equivalent methodology.
A discussion of these methods of analysis is contained in the companion publication,
OSHA 3133, Process Safety Management Guidelines for Compliance. Whichever
method(s) are used, the process hazard analysis must address the following:
The hazards of the process;
The identification of any previous incident that had a potential for catastrophic
consequences in the workplace;
Engineering and administrative controls applicable to the hazards and their
interrelationships, such as appropriate application of detection methodologies to
provide early warning of releases. Acceptable detection methods might include
process monitoring and control instrumentation with alarms, and detection
hardware such as hydrocarbon sensors;
Consequences of failure of engineering and administrative controls;
Facility siting;
Human factors; and
A qualitative evaluation of a range of the possible safety and health effects on
employees in the workplace if there is a failure of controls.
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R10 Risk Management Training Manual EPA 910-K-10-001 March 2010
OSHA believes that the process hazard analysis is best performed by a team with
expertise in engineering and process operations, and that the team should include at
least one employee who has experience with and knowledge of the process being
evaluated. Also, one member of the team must be knowledgeable in the specific
analysis methods being used.
The employer must establish a system to address promptly the team's findings and
recommendations; ensure that the recommendations are resolved in a timely manner
and that the resolutions are documented; document what actions are to be taken;
develop a written schedule of when these actions are to be completed; complete actions
as soon as possible; and communicate the actions to operating, maintenance, and other
employees whose work assignments are in the process and who may be affected by the
recommendations or actions.
At least every five years after the completion of the initial process hazard analysis, the
process hazard analysis must be updated and revalidated by a team meeting the
standard's requirements to ensure that the hazard analysis is consistent with the current
process.
Employers must keep on file and make available to OSHA, on request, process hazard
analyses and updates or revalidation for each process covered by PSM, as well as the
documented resolution of recommendations, for the life of the process.
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R10 Risk Management Training Manual
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AppatdixF
-74-
WWTP
Checklist for
t-30
Ammonia &ys
Anhydrous Ammonia -Basic Rules
Are storage tank(s} painted white or other light reflecting caters
and maintained in good older?
k storage area free of readily ignitablematerials?
Are storage tank(s} kept away from wells or other sources of
potable water aupplyt
Aie storage tank(s) located with ample working space all around?
Are storage tank(s) properly vented and away from areas where
operataix are likely to be?
Does receiving system include a vapor return?
b storage capacity adequate to receive full volume of delivery
vehicle?
Aie storage tankfsj secured against overturn by wind, earthquake
and/or floatation?
AK tank bottam(s) protected from external corrosion?
Is aqua ammonia system protected from possible damaj^ from
moving vehicles?
Are storage tank(i} labeled as to content?
Are all appurtenances suitable for aqua ammonia service?
Are all storage tank(s) Fitted with liquid level gauges?
Are liquid level gauge(s) adequately protected from physical
damage?
If tubing is used, is it fitted with a fail closed valve?
Are all storage tank(s) fitted with overfill fittings or high level
alarms?
Are tank(s } fitted with pressure/vacuum valves?
is an ammonia gas scrubber system used?
Are piping and hose materials suitable for aqua ammonia service?
ฅest*WNA
Comments
General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR
Part 68). EPA-550-B-04-001 April 2004
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R10 Risk Management Training Manual
EPA 910-K-10-001 March 2010
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R10 Risk Management Training Manual
EPA 910-K-10-001
March 2010
Process Hazard Analysis or
Hazard Review
Program Levels:
There are three program levels.
A facility program level is determined
by the result of the off site
consequence analysis and whether
or not it is subject to the OSHA PSM
standard.
Program 1
o The off site consequence analysis proves
that a catastrophic release (worst case
scenario) does not reach a public receptor
or an environmental receptor.
o Also has not had an incident that caused
a death, injury or a restoration response
for an environmental receptor
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R10 Risk Management Training Manual
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Program 3
o The process is subject to the OSHA
process safety management
standard, 29CFR 1910.119
o The process in the NAICS code
32211, 32411, 32511, 325181,
325188, 325192, 325199,325211,
325311 or 32532.
Program 2
o The off site consequence analysis
proves that a catastrophic release
(worst case) would reach a public or
environment receptor but the facility
does not meet the requirements of
Program 3.
Program 2 - Hazard Review
Conduct a review of the hazards of the regulated process.
Identify opportunities for equipment malfunction
or human error.
Identify safeguards used or needed to prevent
such occurrences.
Identify the steps used or needed to detect or
monitor releases
Document the results and ensure the problems
identified are resolved in a timely manner.
Review and update at least every 5 years and
or when major changes occur.
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Process Hazard Analysis -Program 3
The owner or operator shall perform an initial process
hazard analysis (PHA), and identify, evaluate, and
control the hazards involved in the process,
Why a Process Hazard Analysis?
o To identify activities or occurrences that
are potential safety problems.
o To determine and develop corrective
measures needed to reduce or eliminate
the exposure.
o To establish a system to assure that all
findings and recommendations are
addressed.
Types of Process Hazard Analysis Allowed
o What-if
o Checklist
o What-if/Checklist
o Hazard and Operability Study (HAZOP)
o Failure Mode and Effects Analysis
o Fault Tree Analysis
o An appropriate equivalent methodology
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Let's look at a "What if" concept
o Develop a PHA team to ask questions
pertaining to actions, processes and
procedures that occur within an operation.
o Each question addresses a potential failure
in operating or maintenance procedures or
an activity that could effect a process in an
adverse way.
The PHA Team
o The PHA mus t be p erformed by a team wit h
expertise in engineering and process operations
and the team must include appropriate personnel.
o The t earn must i nclude on e employee that is
familiar with the process and one individual that is
familiar with the PHA methodology being used.
Example questions
o Do the operating procedures address the
possibility of a release during power outage?
o Are the inspections of the power hoists
adequate?
o Are the fork truck masts tall enough to impact
the overhead piping or equipment?
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Examples: Responses
o Power outages are adequately addressed in the
operating procedures and operator training.
o The hoists are being inspected monthly as per
the manufacturers recommendations and OS HA
requirements.
o The fork trucks could make contact with several
evaporators in the cold storage warehouse.
PHA : Fork truck operations
o Exposure was identified.
o Need to determine actions that will reduce and or
eliminate the exposure.
o Need to prioritize and document the actions that are
needed, (time line, responsibility, etc.)
o Need to establish a tracking system for comple;
o Do not overlook accountability
Did the PHA address
The hazards of the process?
Identification of any incident that had a likely potential for
catastrophic consequences?
Engineering and administrative controls applicable to
hazards and interrelationships?
Consequences of failure of engineering and administrative
controls?
Stationary source siting?
Human factors?
An evaluation of a range of the possible safety and health
effects of failure of controls?
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System to address the team findings
o The owner or operator shall established a system
to p romptly add ress the team's f indings and
recommendations;
o Assure that the recommendations are resolved in
a timely manner and documented; document what
actions are to be taken;
o Complete actions as soon as possible;
o Develop a written schedule of when these actions
are to be completed;
o Communicate t he actions to operating,
maintenance, and other employees whose work
assignments are in the process and who may be
affected by the recommendations.
5 year up-dates
o The PHA must be updated and revalidated by a
team every five years after the completion of the
initial PHA to assure that the PHA is consistent
with the current process,
Document Retention
o The owner or operator must retain the
PHA's and updates or revalidations for
each process covered, as well as the
resolution of recommendations, for the life
of the process.
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Operating Procedures
Operating procedures describe tasks to be performed, data to be recorded, operating
conditions to be maintained, samples to be collected, and safety and health precautions
to be taken. The procedures need to be technically accurate, understandable to
employees, and revised periodically to ensure that they reflect current operations. The
process safety information package is to be used as a resource to better assure that the
operating procedures and practices are consistent with the known hazards of the
chemicals in the process and that the operating parameters are accurate. Operating
procedures should be reviewed by engineering staff and operating personnel to ensure
that they are accurate and provide practical instructions on how to actually carry out job
duties safely.
Operating procedures will include specific instructions or details on what steps are to be
taken or followed in carrying out the stated procedures. These operating instructions for
each procedure should include the applicable safety precautions and should contain
appropriate information on safety implications. For example, the operating procedures
addressing operating parameters will contain operating instructions about pressure
limits, temperature ranges, flow rates, what to do when an upset condition occurs, what
alarms and instruments are pertinent if an upset condition occurs, and other subjects.
Another example of using operating instructions to properly implement operating
procedures is in starting up or shutting down the process. In these cases, different
parameters will be required from those of normal operation. These operating instructions
need to clearly indicate the distinctions between startup and normal operations such as
the appropriate allowances for heating up a unit to reach the normal operating
parameters. Also the operating instructions need to describe the proper method for
increasing the temperature of the unit until the normal operating temperature parameters
are achieved.
Computerized process control systems add complexity to operating instructions. These
operating instructions need to describe the logic of the software as well as the
relationship between the equipment and the control system; otherwise, it may not be
apparent to the operator.
Operating procedures and instructions are important for training operating personnel.
The operating procedures are often viewed as the standard operating practices (SOPs)
for operations. Control room personnel and operating staff, in general, need to have a
full understanding of operating procedures. If workers are not fluent in English then
procedures and instructions need to be prepared in a second language understood by
the workers. In addition, operating procedures need to be changed when there is a
change in the process as a result of the management of change procedures. The
consequences of operating procedure changes need to be fully evaluated and the
information conveyed to the personnel.
Source: OSHA Guidance on PSM (1910.119), Appendix D: page D-5
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For example, mechanical changes to the process made by the maintenance department
(like changing a valve from steel to brass or other subtle changes) need to be evaluated
to determine if operating procedures and practices also need to be changed. All
management of change actions must be coordinated and integrated with current
operating procedures and operating personnel must be oriented to the changes in
procedures before the change is made. When the process is shutdown to make a
change, then the operating procedures must be updated before startup of the process.
Training in how to handle upset conditions must be accomplished as well as what
operating personnel are to do in emergencies such as when a pump seal fails or a
pipeline ruptures. Communication between operating personnel and workers performing
work within the process area, such as non-routine tasks, also must be maintained. The
hazards of the tasks are to be conveyed to operating personnel in accordance with
established procedures and to those performing the actual tasks. When the work is
completed, operating personnel should be informed to provide closure on the job.
Source: OSHA Guidance on PSM (1910.119)
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Operating Procedure Requirements Summary
March 2010
Steps for Each Phase
Initial startup
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following a normal or emergency shutdown
or major change
Lockout/tagout*
Confined space entry*
Opening process equipment or piping*
Entrance into the facility*
Operating Limits
Consequences of deviations
Steps to avoid, correct deviations
Equipment Inspection
Safety & Health Considerations
Chemical properties & hazards
Precautions for preventing chemical exposure
Control measures for exposure
QC for raw materials and chemical inventory
Special or unique hazards
Safety Systems & Their Functions
What systems are there and how do they work
Annual Certification Requirement
Conduct annual certification
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Operating Procedures
Must be:
n Appropriate for the equipment and operations
n Complete
n Easily understood by facility's operators
n Readily accessible to workers who operate or
maintain the process
Review/modify as often as necessary to
reflect current practices and process
changes
Operating Procedure
Requirements Summary
Initial startup
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following a normal or
emergency shutdown or major change
Lockout/tag out*
Confined space entry*
Opening process equipment or piping*
Entrance into the facility*
ซ
ซ
ซ
ซ
ซ
ซ
ซ
ซ
Operating Procedure
Requirements Summary
| What systems are there and how do they work
^^^^^^^^^^^^^^^^^m
Conduct annual certification
EPARegion 10
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Operating Procedures
m
Must give clear
instructions for safety
conducting activities
involving a covered
process
Steps must include:
n Initial start-up
n Normal operations
D Temporary operations
D Emergency operations
n Normal shut down
n Start-up following
emergency or major
change
Operating Procedures
Must have:
n Consequences of
deviations
n Steps required to
correct or avoid
deviation
Know your
operating limits!!
Operating Procedures
D Safety and health
considerations:
Properties of, and physical
hazards presented by, the
chemicals used in the
process
h Precautions necessary to
prevent exposure,
including engineering
controls, administrative
controls, and personal
protective equipment
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Operating Procedures
i Control measures
to be taken if
physical contact or
airborne exposure
occurs
i Quality control for
raw materials and
control of
hazardous chemical
inventory levels
i Any special or
unique hazards
Operating Procedures
Operating procedures
must be readily
accessible to
employees who are
involved in a process.
Operating Procedures
Procedures must be current
and accurate and that
procedures have been
reviewed as often as
necessary.
Must certify annually!!
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Training
Site-specific, up-to-date, and documented employee training programs are crucial to
ensure that employees understand their job in relation to the chemical process, its
hazards, and the precautions necessary to prevent process safety incidents. (CCPS)
Employee Training: All employees, including maintenance and contractor employees,
involved with highly hazardous chemicals need to fully understand the safety and health
hazards of the chemicals and processes they work with for the protection of themselves,
their fellow employees and the citizens of nearby communities. Training conducted in
compliance with OSHA 1910.1200, the Hazard Communication standard, will help
employees to be more knowledgeable about the chemicals they work with as well as
familiarize them with reading and understanding MSDS. However, additional training in
subjects such as operating procedures and safe work practices, emergency evacuation
and response, safety procedures, routine and nonroutine work authorization activities,
and other areas pertinent to process safety and health will need to be covered by an
employer's training program.
In establishing their training programs, employers must clearly define the employees to
be trained and what subjects are to be covered in their training. Employers in setting up
their training program will need to clearly establish the goals and objectives they wish to
achieve with the training that they provide to their employees. The learning goals or
objectives should be written in clear measurable terms before the training begins. These
goals and objectives need to be tailored to each of the specific training modules or
segments. Employers should describe the important actions and conditions under which
the employee will demonstrate competence or knowledge as well as what is acceptable
performance.
Hands-on-training where employees are able to use their senses beyond listening, will
enhance learning. For example, operating personnel, who will work in a control room or
at control panels, would benefit by being trained at a simulated control panel or panels.
Upset conditions of various types could be displayed on the simulator, and then the
employee could go through the proper operating procedures to bring the simulator panel
back to the normal operating parameters. A training environment could be created to
help the trainee feel the full reality of the situation but, of course, under controlled
conditions. This realistic type of training can be very effective in teaching employees
correct procedures while allowing them to also see the consequences of what might
happens if they do not follow established operating procedures. Other training
techniques using videos or on-the-job training can also be very effective for teaching
other job tasks, duties, or other important information. An effective training program will
allow the employee to fully participate in the training process and to practice their skill or
knowledge.
Source: OSHA Guidance on PSM (1910.119)
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RMP TRAINING REQUIREMENTS
Common Deficiencies
No date or employee ID on Training Records
No description of training or testing methods
No documentation of initial or 3-year refresher training
Purpose of a training program
Provides workers with the information they need to:
Understand how to operate safely, and
Why safe operations are necessary
Owner/Operator Responsibility
Provide initial training to all workers in the covered process including
safety and health hazards, operating procedures, emergency operations
including shutdown and safe work practices
Provide refresher training at least every three years
Ascertain and document that each employee received and understood
the training,
O/O shall prepare a record which contains:
Employee ID,
Date of training, and
The means used to verify that the employee understood the training
Training requirements for other Prevention Program (3) Elements
Mechanical integrity - Training for process maintenance activities
Management of change & Pre-startup review - Training of each employee
involved in operating a process has been completed in any updated or new
procedures prior to startup of a process after a major change
Contractors
The contract O/O shall assure that each contract employee is trained
Has received and understood the training,
Identity of the contract employee, the date of training, and the means used to
verify that the employee understood is documented
Emergency response program
Training for all employees in relevant procedure
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TRAINING DOCUMENTATION FORM - SAMPLE
Topics:
Accident Prevention Program, safety orientation
Personal Protective Equipment Type:
Chemical Hazard Communication
First Aid
Portable Fire Extinguishers
Date(s) of Training:
List of employees who completed
this training:
Testing Method and Results
Trainer/Employer
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Operator Certification Form
Name: SSN:
Job Title/Position: Process Area/Dept:
This document certifies that as of June 21,1999, this employee has the required knowledge, skill and
abilities to safety carry out duties and responsibilities as specified in the operating procedures for the
following process(es):
(1) (2)
(3) (4)
(5) (6)
(7) (8)
(9) (10)
(11) (12)
Employee Signature:
Name: Date:
Supervisor Signature:
Supervisor Name: Date:
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Training
A training program,
Provides workers with the
information they need to:
Understand how to
operate safely, and
Why safe operations are
necessary
Ensures that the rest of the
prevention program is
effective
Training Program Elements
Operating Procedures
Maintenance or Mechanical Integrity
Management of Change and Pre-Startup
Contractor
Emergency Response
Program 2 & 3
Operating Procedure Training
Initial Training -
Presently operating a process, and newly
assigned to a covered process:
Have been trained or tested competent in the
operating procedures and safe work practices
Employees operating a process on June 21, 1999;
O/O certification
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Program 2 & 3
Operator Training Requirements
Refresher training
At least every three
years
Maintenance - Program (2)
Mechanical Integrity - Program (3)
> Hazards of the
process
' How to avoid or
correct an
unsafe
condition
' Procedures
applicable to
job tasks
Management of Change and
Pre-Startup Training
Operators, maintenance
and contract employees
must be trained in any
updated or new procedures
prior to startup of a process
after a major change
Training must be complete
prior to introduction of
regulated substance to a
new or changed process
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Emergency Response Training
Employees
must be trained
in relevant ER
procedures -
Document
Contractor Must Insure Contract
Employees are Trained in:
Safe work practices
Known hazards and
emergency response
activities (Program 3)
Maintenance
procedures related to
process hazard
Training Documentation
Owner/Operator Requirements
Ascertain that each employee:
Received and understood the training,
Prepare a record which contains:
Employee ID,
Date of training, and
The means used to verify that the employee
understood the training
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Training Basics
Site-specific
Up-to date
Documented
Training Deficiencies
No date or employee ID on
Training Records
No description of training or
testing methods
No documentation of initial or
3-year refresher training
RMP Prevention
Program
Training Requirements
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Employee Participation
Common Deficiencies:
Failure to develop a written plan of action regarding the implementation of the
employee participation
Failure to consult with employees and their representatives on the conduct and
development of process hazards analyses
Failure to provide employees and their representatives access to process
hazards analyses and to all other information required to be developed under the
chemical accident prevention rule
Because of their first-hand knowledge of problems and practical solutions, non-
supervisory employees (operators, mechanics, etc.) should be included in the process.
(CCPS)
The employee participation rule applies to Program 2 and 3 facilities. It requires you to
consult with your employees and their representatives on the conduct and development
of process hazards analyses and other required process safety management elements.
The Risk Management Program is a tool to be used by everyone in a facility, not just
management. Parent company developed RMPs should have local input, review and
relevance.
The table below briefly summarizes what you must do:
Program 3 Facilities: EMPLOYEE PARTICIPATION REQUIREMENTS
Write a plan
Consult with
employees
Provide access to
information
Develop a written plan of action regarding how you will implement
employee participation.
Consult your employees and their representatives regarding conducting
and developing PHAs and other elements of process safety management
in the risk management program rule.
Review and certify operating procedures
Determine frequency of training with employee input* (Program 2)
Review maintenance procedures, use of equipment and need for
upgrade or retrofit* (Program 2)
Review incident investigations with all affected personnel*
(Program 2)
Ensure that your employees and their representatives have access to
PHAs and all other information required to be developed under the rule.
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Prevention Program
Employee Participation
Employee Participation
Because of their first-
hand knowledge of
problems and
practical solutions,
non-supervisory
employees
(operators,
mechanics, etc.)
should be included in
the process. (CCPS)
Employee Participation - Defined
Consult with employees and their
representatives on the conduct and
development of:
Process hazards analyses
Other process safety management
elements in chemical accident prevention
provisions.
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Employee Participation
Requirements
Written plan of action
regarding the
implementation of
the employee
participation.
Plan Might Address
Training - topic and
frequency
Mechanism for
Operator Input
Contact
Scheduled review
Availability of PHA
documents
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Mechanical Integrity
OSHA believes it is important to maintain the mechanical integrity of critical process
equipment to ensure it is designed and installed correctly and operates properly. PSM
mechanical integrity requirements apply to the following equipment:
Pressure vessels and storage tanks;
Piping systems (including piping components such as valves);
Relief and vent systems and devices;
Emergency shutdown systems;
Controls (including monitoring devices and sensors, alarms, and interlocks);
and
Pumps.
The employer must establish and implement written procedures to maintain the ongoing
integrity of process equipment. Employees involved in maintaining the ongoing integrity
of process equipment must be trained in an overview of that process and its hazards and
trained in the procedures applicable to the employees' job tasks.
Inspection and testing must be performed on process equipment, using procedures that
follow recognized and generally accepted good engineering practices. The frequency of
inspections and tests of process equipment must conform with manufacturers'
recommendations and good engineering practices, or more frequently if determined to
be necessary by prior operating experience. Each inspection and test on process
equipment must be documented, identifying the date of the inspection or test, the name
of the person who performed the inspection or test, the serial number or other identifier
of the equipment on which the inspection or test was performed, a description of the
inspection or test performed, and the results of the inspection or test.
Equipment deficiencies outside the acceptable limits defined by the process safety
information must be corrected before further use. In some cases, it may not be
necessary that deficiencies be corrected before further use, as long as deficiencies are
corrected in a safe and timely manner, when other necessary steps are taken to ensure
safe operation.
In constructing new plants and equipment, the employer must ensure that equipment as
it is fabricated is suitable for the process application for which it will be used. Appropriate
checks and inspections must be performed to ensure that equipment is installed properly
and is consistent with design specifications and the manufacturer's instructions.
The employer also must ensure that maintenance materials, spare parts, and equipment
are suitable for the process application for which they will be used.
Source: OSHA Guidance on PSM (1910.119)
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Mechanical Integrity
Written procedures
Training
Inspections and testing
Corrective actions
Fabrication/installation of new equipment
Maintenance materials and parts
Written Procedures
Shut down & start up and/or isolation procedures
for each specific task. (LOTO)
Training requirements & methods to assure that
training is adequate, (testing should be considered )
Inspection/testing procedures addresses needed
frequency & operational tolerances.
Methods for assuring that new equipment or
modifications to existing equipment are suitable
for the process. (MOC covers this)
Inspection Practices
Follow recognized and generally good
engineering practices for inspections and
testing.
n Manufactures recommendations
n Industry standards (ASME, NFPA, MAR, Etc.)
n Prior operating experience
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Pressure Relief Devices
MAR Bulletin 110, Section 6.6.3
(Excerpts)
Revision: May 24, 2007
Pressure relief devices shall be replaced or recertified in accordance with
one of these three options:
1. Every five (5) years from the date of installation.
MAR originally recommended (in 1978) that pressure relief valves be
replaced every five years from the date of installation. This
recommendation represents good engineering practice considering the
design and performance of pressure relief devices; or
2. An alternative to the prescriptive replacement interval, i.e., five years, can
be developed based on documented in-service relief valve life for specific
applications using industry accepted good practices of relief valve
evaluation; or
3. The manufacturer's recommendations on replacement frequency of
pressure relief devices shall be followed.
Exception: Relief devices discharging into another part of the closed-loop refrigeration
system are not subject to the relief valve replacement practices.
Inspection Frequency
Ensure frequency of inspections and tests
consistent with applicable manufacturers'
recommendations, good engineering practices,
and prior operating experience.
n Hourly
n Daily
n Monthly
nAnnually
n Manufactures recommendations
Inspection Documentation
Document each inspection with
nDate
nName of the person who performed
inspection
n Serial number or other identifier of equipment
n Description
n Results
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Documentation Format
Meets 29 CFR 1910 and 40 CFR 68
Simple to maintain but captures all of the
necessary information
Accountability for both the inspection/test
completion and the documentation of the results
Corrective action (when needed) and
documentation tied to the inspection report.
Documentation Formats
Complexity
Routine checklist
n Hourly task
n Simple items
n Little training required
to execute
Complex checklist
n Hourly or less
n All items can be critical
n Requires extensive
training
Inspection Identified
Equipment Deficiencies
The owner or operator shall correct
deficiencies in equipment that are outside
acceptable limits (defined by the process
safety information in Sec. 68.65) before
further use or in a safe and timely manner
when necessary means are taken to
assure safe operation.
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Design and Installation
Appropriate checks and inspections shall
be performed to assure that equipment is
installed properly and consistent with
design specifications and the
manufacturer's instructions.
Maintenance Materials
The owner or operator shall assure that
maintenance materials, spare parts and
equipment are suitable for the process
application for which they will be used.
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Management of Change/ Pre-startup Safety Review
For existing processes that have been shutdown for turnaround, or modification, etc., the
employer must assure that any changes other than "replacement in kind" made to the
process during shutdown go through the management of change procedures. P&IDs will
need to be updated as necessary, as well as operating procedures and instructions. If
the changes made to the process during shutdown are significant and impact the training
program, then operating personnel as well as employees engaged in routine and non-
routine work in the process area may need some refresher or additional training in light
of the changes. Any incident investigation recommendations, compliance audits or PHA
recommendations need to be reviewed as well to see what impacts they may have on
the process before beginning the startup.
Management of Change Requirements (Program Level 3)'
MOC procedures
must address:
Technical basis for
the change
Impact on safety and
health
Modifications to
operating
procedures
Necessary time
period for the
change
Authorization
requirements for
proposed change
Employees
affected by the
change must:
Be informed of the
change before
startup
Trained in the
change before
startup
Update process safety
information if:
A change covered by
MOC procedures results
in a change in any PSI
required under EPA's
rule (see ง 67.65)
Update
operating
procedures if:
A change
covered by MOC
procedures
results in a
change in any
operating
procedure
required under
EPA's rule (see ง
67.69)
Pre-Startup Safety Review
For new processes, the employer will find a PHA helpful in improving the design and
construction of the process from a reliability and quality point of view. The safe operation
of the new process will be enhanced by making use of the PHA recommendations
before final installations are completed. P&IDs are to be completed along with having the
operating procedures in place and the operating staff trained to run the process before
startup. The initial startup procedures and normal operating procedures need to be fully
evaluated as part of the pre-startup review to assure a safe transfer into the normal
operating mode for meeting the process parameters.
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Interrelationship of Process Safety Management] Elements
An essential part of verifying program implementation is to audit the flow of information
and activities among the [Process Safety Management] elements. When information in
one element is changed or when action takes place in one element that affects other
elements, the Safety Compliance Officers or Health Compliance Officers (SCO/HCO)
shall review a sample of the related elements to see if the appropriate changes and
followup actions have taken place.
The following example demonstrates the interrelationship among the elements:
During a routine inspection of equipment (Mechanical Integrity), the maintenance
worker discovers a valve that no longer meets the applicable code and must be
changed. Because the type of valve is no longer made, a different type of valve must be
selected and installed (Management of Change). The type of valve selected may
mandate different steps for the operators (Operating Procedures) who will require
training and verification in the new procedures (Training). The rationale for selecting the
type of valve must be made available for review by employees and their representatives
(Employee Participation).
When the new valve is installed by the supplier (Contractors), it will involve shutting
down part of the process (Pre-startup Safety Review) as well as brazing some of the
lines (Hot Work Permit). The employer must review the response plan (Emergency
Planning) to ensure that procedures are adequate for the installation hazards.
Although Management of Change provisions cover interim changes, after the new
valve is in place the Process Safety Information will have to be updated before the
Process Hazard Analysis is updated or revalidated, to account for potential hazards
associated with the new equipment. Also, inspection and maintenance procedures and
training will need to be updated (Mechanical Integrity).
In summary, 11 PSM elements can be affected by changing one valve. A SCO/HCO
would check a representative number of these 11 elements to confirm that the required
follow-up activities have been implemented for the new valve.
GENERAL GUIDANCE ON RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENT
PREVENTION (40 CFR PART 68). EPA-550-B-04-001 April 2004
Process Safety Management of Highly Hazardous Chemicals, OREGON OCCUPATIONAL SAFETY
AND HEALTH DIVISION DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, Program
Directive A-177, Issued April 5, 1993, Revised August 15, 2000.
SCO/HCO: Safety Compliance Officers or Health Compliance Officers
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Management of Change
Pre-startup Safety Review
US EPA Region 10
Management of Change ง 68.75
Owner/Operator
Shall
- Establish and
Implement written
procedures to
manage changes
Except for
"replacements in
kind"
US EPA Region 10
Except for "replacements in kind"
US EPA Region 10
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Changes that Affect a Covered Process"
DESCRIPTION OF PROPOSED CHANGE
AND POTENTIAL HAZARDS
Technical basis
Impact on safety and health
Impact on operating
procedures
Time period for the change
Authorization requirements
Affected employees
informed/trained
prior to start-up
Updated process safety
information
DESCRIPTION OF PROPOSED
CHANGE AND POTENTIAL
HAZARDS
US EPA Region 10
Deficiencies: Not Implementing MOC
Have affected personnel (i.e., operations, maintenance, and
contract) been informed of and trained in this change?
Are operating procedures or maintenance procedures required
to be updated as a result of this change?
- If yes, have affected personnel been trained in the updated
operating procedures?
Is the PHA Offisite Consequence Analysis, or RMP applicability
affected by this change?
- If yes, has a hazard assessment update been performed (if
needed) and has the revised RMPIan been submitted?
Is process safety information required to be updated as a result
of this change?
- If yes has a Prestartup Safety Review been performed?
US EPA Region 10
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Pre-startup Safety Review
For modified facilities
where a change is
needed to the
process safety
information
For new facilities
US EPA Region 10
Pre-startup Safety Review
> Evaluate beforehand
Before you push
STABT
Construction & equipment is in
accordance w/ design specs
Safety, operating, maintenance, &
emergency procedures are in place fi
adequate
PHA has been performed and
recommendations resolved for new
facilities
Modified facilities meet the
requirements contained in MOC
Training has been completed for
employees involved in operating the
new process
US EPA Region 10
MOC & PSSR Example
During a routine
inspection, a
maintenance worker
discovers a valve that
no longer meets the
applicable code and
must be changed.
Old Style
Replacement
US EPA Region 10
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MOC & PSSR Example (cont'd)
Management Of Change: Because the type of valve is no longer made, a
different type of valve must be selected and installed.
Operating Procedures: The type of valve selected may mandate different
steps for the operators.
Training: The operators will require training and verification in the new
procedures.
Employee Participation: The rationale for selecting the type of valve must
be made available for review by employees and their representatives.
Process Safety Information: Will have to be updated before the Process
Hazard Analysis is updated or revalidated.
Process Hazard Analysis: Must be updated or revalidated in order to
account for potential hazards associated with the new equipment.
Mechanical Integrity: Inspection and maintenance procedures and training
will need to be updated.
March 2010 US EPA Region 10 10
MOC & PSSR Example (cont'd)
P re-start up Safety Review: Required for modified facilities where a
change is needed to the process safety information.
- Contractors: When the new valve is installed by the supplier it
will involve shutting down part of the process.
- Hot Work Permit: In addition to shutting down part of the
process, some of the lines will need to be welded.
- Emergency Planning: The employer must review the
emergency response plan to ensure that procedures are
adequate for the installation hazards.
US EPA Region 10
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Compliance Audits
Employers need to select a trained individual or assemble a trained team of people to
audit the process safety management system and program. A small process or plant
may need only one knowledgeable person to conduct an audit. The audit is to include an
evaluation of the design and effectiveness of the process safety management system
and a field inspection of the safety and health conditions and practices to verify that the
employer's systems are effectively implemented. The audit should be conducted or led
by a person knowledgeable in audit techniques and who is impartial towards the facility
or area being audited. The essential elements of an audit program include planning,
staffing, conducting the audit, evaluation and corrective action, follow-up and
documentation.
Planning in advance is essential to the success of the auditing process. Each employer
needs to establish the format, staffing, scheduling and verification methods prior to
conducting the audit. The format should be designed to provide the lead auditor with a
procedure or checklist which details the requirements of each section of the standard.
The names of the audit team members should be listed as part of the format as well. The
checklist, if properly designed, could serve as the verification sheet which provides the
auditor with the necessary information to expedite the review and assure that no
requirements of the standard are omitted. This verification sheet format could also
identify those elements that will require evaluation or a response to correct deficiencies.
This sheet could also be used for developing the follow-up and documentation
requirements.
The selection of effective audit team members is critical to the success of the program.
Team members should be chosen for their experience, knowledge, and training and
should be familiar with the processes and with auditing techniques, practices and
procedures. The size of the team will vary depending on the size and complexity of the
process under consideration. For a large, complex, highly instrumented plant, it may be
desirable to have team members with expertise in process engineering and design,
process chemistry, instrumentation and computer controls, electrical hazards and
classifications, safety and health disciplines, maintenance, emergency preparedness,
warehousing or shipping, and process safety auditing. The team may use part-time
members to provide for the depth of expertise required as well as for what is actually
done or followed, compared to what is written.
An effective audit includes a review of the relevant documentation and process safety
information, inspection of the physical facilities, and interviews with all levels of plant
personnel. Using the audit procedure and checklist developed in the preplanning stage,
the audit team can systematically analyze compliance with the provisions of the standard
and any other corporate policies that are relevant. For example, the audit team will
review all aspects of the training program as part of the overall audit. The team will
review the written training program for adequacy of content, frequency of training,
effectiveness of training in terms of its goals and objectives as well as to how it fits into
meeting the standard's requirements, documentation, etc. Through interviews, the team
can determine the employee's knowledge and awareness of the safety procedures,
duties, rules, emergency response assignments, etc. During the inspection, the team
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can observe actual practices such as safety and health policies, procedures, and work
authorization practices. This approach enables the team to identify deficiencies and
determine where corrective actions or improvements are necessary.
An audit is a technique used to gather sufficient facts and information, including
statistical information, to verify compliance with standards. Auditors should select as part
of their preplanning a sample size sufficient to give a degree of confidence that the audit
reflects the level of compliance with the standard. The audit team, through this
systematic analysis, should document areas which require corrective action as well as
those areas where the process safety management system is effective and working in
an effective manner. This provides a record of the audit procedures and findings, and
serves as a baseline of operation data for future audits. It will assist future auditors in
determining changes or trends from previous audits.
Corrective action is one of the most important parts of the audit. It includes not only
addressing the identified deficiencies, but also planning, follow up, and documentation.
The corrective action process normally begins with a management review of the audit
findings. The purpose of this review is to determine what actions are appropriate, and to
establish priorities, timetables, resource allocations and requirements and
responsibilities. In some cases, corrective action may involve a simple change in
procedure or minor maintenance effort to remedy the concern. Management of change
procedures need to be used, as appropriate, even for what may seem to be a minor
change. Many of the deficiencies can be acted on promptly, while some may require
engineering studies or in-depth review of actual procedures and practices. There may be
instances where no action is necessary and this is a valid response to an audit finding.
All actions taken, including an explanation where no action is taken on a finding, needs
to be documented as to what was done and why.
It is important to assure that each deficiency identified is addressed, the corrective action
to be taken noted, and the audit person or team responsible be properly documented by
the employer.
To control the corrective action process, the employer should consider the use of a
tracking system. This tracking system might include periodic status reports shared with
affected levels of management, specific reports such as completion of an engineering
study, and a final implementation report to provide closure for audit findings that have
been through management of change, if appropriate, and then shared with affected
employees and management. This type of tracking system provides the employer with
the status of the corrective action. It also provides the documentation required to verify
that appropriate corrective actions were taken on deficiencies identified in the audit.
Source: OSHA Guidance on PSM (1910.119)
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RMP Compliance Audit Requirements
Title 40: PART 68CHEMICAL ACCIDENT PREVENTION PROVISIONS
Subpart CProgram 2, ง 68.58, Subpart DProgram 3, ง 68.79
Common Deficiencies:
> Not completed at least every three years
> Do not identify and review all RMP elements
> Checklist not site-specific
> Do not identify who is responsible for addressing deficiencies
> No date when deficiencies were corrected
> How the deficiencies were addressed
> Findings and recommendations not addressed
> Resolutions/ corrections not documented
> Failure to address previous PHA
> Failure to ensure all written procedures are consistent
> Failure to certify audit
Purpose of a compliance audit:
Evaluate and measure the effectiveness of your risk management program
(RMP):
o Reviews each of the prevention program elements
1. Ensure RMP is up-to-date and being implemented
2. Identify problem areas and take corrective actions
Run a safer operation.
Owner/Operator responsibility:
Certify that they have evaluated compliance at least every three years to verify
that the procedures and practices developed under the rule are adequate and
are being followed.
Have at least one person knowledgeable in the process.
Develop a report of the audit findings.
Promptly determine and document an appropriate response to each of the
findings and document that deficiencies have been corrected.
Retain the two (2) most recent compliance audit reports. This requirement does
not apply to any compliance audit report that is more than five years old.
Prevention Program Elements
-S Safety Information
v' PHA/Hazard Review
S Operating Procedures
-S Training
S Maintenance/Mechanical Integrity
S Compliance Audits
-S Incident Investigation
S Management of Change (MOC)
S Pre-startup Safety Review
-S Hotwork
S Contractors - Employee Participation
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Risk Management Program
Compliance Audits
CA Program Level Requirements
Program 2
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance Mechanical Integrity
Compliance Audits
Incident Investigation
Program 3
Process Safety Information
Processes Hazard Analysis
Operating Procedures
Training
Maintenance Mechanical Integrity
Management of Change
Pre-Startup Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Perm it
Contractors
March 2010 EPA Region 10 2
Compliance Audits Process
At least one person
knowledgeable of the
process.
Document findings, ^
responses and corrections of
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Compliance Audits
Documentation
Document findings,
responses and corrections of
any deficiencies
Identify problem
areas and take
corrective actions.
Compliance Audits Common
Deficiencies
Not completed at least every three years
Did not identify and review all RMP elements
Checklist not site-specific
Did not identify who is responsible for addressing
deficiencies
Failure to address previous PHA
Failure to ensure all written procedures are consistent
Failure to certify audit
No date when deficiencies were corrected
How were the deficiencies addressed
Findings and recommendations not addressed
Resolutions/ corrections not documented
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Hot Work Permit
Non-routine work which is conducted in process areas needs to be controlled by
the employer in a consistent manner. The hazards identified involving the work
that is to be accomplished must be communicated to those doing the work, but
also to those operating personnel whose work could affect the safety of the
process. A work authorization notice or permit must have a procedure that
describes the steps the maintenance supervisor, contractor representative or
other person needs to follow to obtain the necessary clearance to get the job
started. The work authorization procedures need to reference and coordinate, as
applicable, lockout/tagout procedures, line breaking procedures, confined space
entry procedures and hot work authorizations. This procedure also needs to
provide clear steps to follow once the job is completed to provide closure for
those that need to know the job is now completed and equipment can be
returned to normal.
Source: OSHA Guidance on PSM (1910.119)
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UF HOT WORK PERMIT
This Hot Work Permit is required for any operation involving open flames or producing heat and/or
sparks and must be completed by a Competent Hot Work Supervisor (CHWS) and posted at the site.
Hot Work includes, but is not limited to: Brazing, Torch Cutting, Grinding, Soldering, and Welding.
If the required precautions cannot be met, Hot Work is not permitted.
HOT WORK DONE BY
| CONTRACTOR
DATE:
WO#
BUILDING NAME, BLDG #, ROOM #, LOCATION
NATURE OF JOB
NAME OF HOT WORK OPERATOR
I verify the above location has been examined, the precautions
checked on the Required Precautions Checklist have been
taken to prevent fire, and permission is authorized for work.
NAME OF COMPETENT HOT WORK SUPERVISOR
(CHWS)
Contact #
Fax*
PERMIT
REQUEST
PERMIT
EXPIRES
DATE
DATE
SIGNATURE OF CHWS
To be signed during inspection
EH&S Approval
REQUIRED PRECAUTIONS CHECKLIST
Q] Available sprinklers, hose streams,
and extinguishers are in service/operable.
Q] Hot work equipment in good repair.
Requirements within 35ft of work
Q| Flammable liquids, dust, lint and
oil deposits removed.
] Explosive atmosphere in area eliminated.
Q| Floors swept clean of combustibles.
I Combustible floors wet down,
Combustible floors wet down,
covered with damp sand or fire-
resistant sheets.
Remove other combustibles where
possible. Otherwise protect with
fire-resistant tarpaulins, screens or
shields.
All wall and flj^^xpeninffs covered.
Fire-resistant tarpaulins suspended
beneath elevated hot work.
Work on walls or ceilings/enclosed equipment
Construction is noncombustible and without
combustible covering or insulation.
Combustibles on other side of walls
wed away.
danger emsts by conduction of heat into
ranother room or area
Enclosed equipment cleaned of all
combustibles.
^ntainers purged of flammable liquids
and vapors.
Fire watch/hot work area monitoring.
Fire watch will be provided during and
continuously for 30 minutes after work,
including during any work breaks.
Fire watch is supplied with suitable
extinguishers.
Fire watch is trained in use of this equipment
and in sounding alarm.
Q| Fire watch may be required for adjoining
areas, above and below.
Q| Hot work area inspected 30 minutes after
job is completed.
Other precautions Taken
Q| Confined space entry permit required.
Q| Area is protected with smoke or heat
detection.
Q| Ample ventilation to remove smoke/vapor
from work area.
O Lockout/tagout required.
Comments:
| Submit Form
FAX TO EH&S ฉ352-392-6367 PRIOR TO 8:OOAM OF PERMIT REQUEST DATE
This Permit was developed for compliance with:
EH&S HOT WORK SAFETY POLICY UFEHS-SAFE1-07/22/2003
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Contractors
Employers who use contractors to perform work in and around processes that
involve highly hazardous chemicals, will need to establish a screening process
so that they hire and use contractors who accomplish the desired job tasks
without compromising the safety and health of employees at a facility. For
contractors, whose safety performance on the job is not known to the hiring
employer, the employer will need to obtain information on injury and illness rates
and experience and should obtain contractor references. Additionally, the
employer must assure that the contractor has the appropriate job skills,
knowledge and certifications (such as for pressure vessel welders). Contractor
work methods and experiences should be evaluated. For example, does the
contractor conducting demolition work swing loads over operating processes or
does the contractor avoid such hazards?
Contract employees must perform their work safely. Considering that contractors
often perform very specialized and potentially hazardous tasks such as confined
space entry activities and non-routine repair activities it is quite important that
their activities be controlled while they are working on or near a covered process.
A permit system or work authorization system for these activities would also be
helpful to all affected employers. The use of a work authorization system keeps
an employer informed of contract employee activities, and as a benefit the
employer will have better coordination and more management control over the
work being performed in the process area. A well run and well maintained
process where employee safety is fully recognized will benefit all of those who
work in the facility whether they be contract employees or employees of the
owner.
Source: OSHA Guidance on PSM (1910.119)
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SAMPLE DOCUMENT
ZIP
RISK IDENTIFICATION NO.
EFFECTIVE DATE OF RATING
FEDERAL IDENTIFICATION NUMBER
STATE OF COVERAGE
Coverage Period
(1)
Effective
Month/Day/
Year
(2)
Expiration
Month/Day/
Year
(3)
Class
Code
(4)
Payroll
(5)
Claim
Identification
Number Assigned
(6)
Injury
Type
Code
(?)
Open/Closed
-Final
(0/F)
(8)
Incurred Losses
(Paid plus
Reserves)
PLEASE FOLLOW THE INSTRUCTIONS ON THE BACK PAGE FOR COMPLETING THIS WORKSHEET, AND
RETURN IT TO NCCI PRIOR TO THE RATING EFFECTIVE DATE.
ERM-6{Rev. 12/03)
Page 1 of 2
ฃ 2002 National Council ฉn Compensation Insurance* Inc.
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Hot Work Permit
o Permit for each hot work operation conducted on
or near a covered process.
o The permit shall document that the fire
prevention and protection requirements in 29CFR
1910.252(a) have been implemented prior to
beginning the hot work operations.
o The permit shall indicate the date(s) authorized
for hot work and the object(s) upon which hot
work is to be performed.
o The permits shall be kept on file until completion
of the hot work operations.
Contractors
o Requires that the owner or operator has
obtained and evaluated contract owner
or operator's safety performance and
programs before selecting the contractor
How does your contracting or finance
office fulfill this requirement?
Do you review the State OSHA website
for injuries or accident/insurance claims?
Facility Responsibilities
o Inform the contract owner or operator of the known
potential fire, explosion, or toxic release hazards
related to the contractor's work and the process.
o Explain to the contract owner or operator the
applicable provisions of the emergency response or
the emergency action program.
o Develop and implement safe work practices
consistent with ง68.69(d), to control the entrance,
presence, and exit of the contract owner or operator
and contract employees in the covered process areas.
o Periodically evaluate contractor in meeting their
responsibilities
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OSHA / WISHA Report Forms
Workers Compensation experience rating report
E -7T
BP Texas City Explosion
I 15 fatalities
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Incident Investigations
Incident investigation is the process of identifying the underlying causes of incidents and
implementing steps to prevent similar events from occurring. The intent of an incident
investigation is for employers to learn from past experiences and thus avoid repeating
past mistakes. Some of the events are sometimes referred to as "near misses," meaning
that a serious consequence did not occur, but could have.
Employers need to develop in-house capability to investigate incidents that occur in their
facilities. A team needs to be assembled by the employer and trained in the techniques
of investigation including how to conduct interviews of witnesses, needed documentation
and report writing. A multi-disciplinary team is better able to gather the facts of the event
and to analyze them and develop plausible scenarios as to what happened, and why.
Team members should be selected on the basis of their training, knowledge and ability
to contribute to a team effort to fully investigate the incident.
Employees in the process area where the incident occurred should be consulted,
interviewed or made a member of the team. Their knowledge of the events form a
significant set of facts about the incident which occurred. The report, its findings and
recommendations are to be shared with those who can benefit from the information. The
cooperation of employees is essential to an effective incident investigation. The focus of
the investigation should be to obtain facts, and not to place blame. The team and the
investigation process should clearly deal with all involved individuals in a fair, open and
consistent manner.
Source: OSHA Guidance on PSM (1910.119), Appendix D: page D-11
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Requirements
Initiate an investigation promptly, but
within 48 hours.
Assemble an Investigation Team.
Summarize the investigation in a
report.
Address findings/recommendations.
Review the report with your
staff/contractors.
Retain Report for Five Years.
Program 2
X
X
X
X
X
Program 3
X
X
X
X
X
X
Important to Remember:
Does this meet Five-Year Accident History criteria?
o Required to submit RMP correction within 6 months.
Does this incident impact other Prevention Program elements?
At a Minimum, Key Elements should always be routinely reviewed
following an incident:
Operating Procedures;
Maintenance Procedures;
Process Hazard Analysis; and
Training
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Incident Investigation
Risk Management Program
i
What's an Incident?
Definitions
Incident - Event which resulted in, or
could reasonably have resulted in a
catastrophic release of a regulated
substance, (includes near misses)
Incident Investigation - Written analysis of
an accident/incident using various methods of
causal determination.
Catastrophic Release - One that presents an
imminent and substantial endangerment to
public health and the environment.
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Examples of
Catastrophic Releases
i Process fires
i Explosions
i Reportable spills and
releases
i Flammable, toxic, or
reactive piping
failures
i Line breaking
accidents
i Equipment failures
Requirements for
an Investigation
Begin within 48
hours of accident or
incident.
Establish
knowledgeable
investigation team.
Summarize the
investigation in a
written report.
Incident Investigation
Requirements
Initiate an investigation
promptly, but within 48 hrs.
Assemble Investigation Team.
Summarize the investigation
in a report.
Address
findings/recommendations.
Review the report with your
staff/contractors.
Retain Report for Five Years.
Program 2
X
X
X
X
X
Program 3
X
X
X
X
X
X
March 2010 EPA Region 10
6
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Incident Investigation
Important to Remember:
. Does this meet Five-Year Accident
History criteria?
Required to submit RMP correction within i
months.
. Does this incident impact other
Prevention Program elements?
Incident Investigation
Prevention Program Elements
At a Minimum, Key Elements
should always be routinely
reviewed following an incident:
Operating Procedures;
Maintenance Procedures;
Process Hazard Analysis; and
Training
Incident Resolution
Employer must either:
Adopt the incident
investigation team's
recommendation or
Justifiably decline to
adopt the
recommendations
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Declining Recommendations
Owner/Operator must:
Inform team members;
Document the justification in writing:
. Analysis and recommendations were based on
factual errors
. Recommendation not necessary to protect
employees, contractors, or the public
. Alternative measure would provide sufficient
protection
. Recommendation presented was not feasible for
adoption
Incident Investigations
at Progressive Companies
Not merely looking at only the specific findings,
but look beyond "what broke"
Determine root cause to ensure recurrence is
eliminated, if possible
Look at management systems and organizational
structure that could be improved
Use information from investigation to assess the
program
All incidents are investigated, including "near
misses"
Goals of the Investigation
Use investigation as a
program management
tool
Prevents injuries
Prevent process
shutdown
Prevent recurrence
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Emergency Response
RISK MANAGEMENT PROGRAM REQUIREMENTS
40 CFR 68 Subpart E - Emergency Response
Does not apply to facilities that exclusively have Risk Management Program Level 1
processes;
All facilities with Program Level 2 or Program Level 3 processes are required to
comply. If a facility has at least one Program 2 or Program 3 process, Part 68
requires the facility to implement an emergency response program if its employees
will respond to some releases involving regulated substances.
Facilities have two options when developing programs to address accidental releases of
regulated substances. The choices are:
1. Evacuate their employees and use coordinated response plans with local fire
departments and/or community emergency response resources (non-
responding facility) or
2. Have their employees respond to accidental releases of regulated
substances (a responding facility)
The requirements of Subpart E are different based on a facility's choice of being a non-
responding facility or a responding facility.
EPA recognizes that, in some cases (particularly for retailers and other small operators
with few employees), it may not be appropriate for employees to conduct response
operations for releases of regulated substances. For example, it would be inappropriate,
and probably unsafe, for an ammonia retailer with only one full-time employee to expect
that a tank fire could be handled without help of the local fire department or other
emergency responders. EPA does not intend to force such facilities to develop
emergency response capabilities. At the same time, the facility is responsible for
ensuring effective emergency response to any release at the facility. If the local public
responders are not capable of providing such responses, the facility must take steps to
ensure that effective response resources are available (e.g., by hiring response
contractors or obtaining agreements with regional hazmat teams).
40 CFR 68.90 - Non-Responding Facilities
As required under OSHA, develop and implement an Emergency Action Plan;
Coordinate with local response agencies:
o Included in the Community Emergency Response Plan in response to a
potential release of a toxic chemical and/or
o Ensure that the local fire department is capable and aware of their
responsibility to respond to a flammable gas fire.
It is recommended that the facility document coordination efforts by keeping copies
of correspondence, posting emergency response contact information and the
procedures that will be used in the event of a response.
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40 CFR 68.95 - Responding Facilities
Must have an Emergency Response Program that protects the public and the
environment;
Emergency Response Program elements must include:
o Written response plan, which includes;
Procedures for informing the public and emergency response
agencies about releases;
Documentation of proper first aid and emergency medical
treatment necessary to treat human exposures;
Procedures and measures for emergency response.
o Procedures for using, inspecting, testing, and maintaining emergency
response equipment;
o Training for employees;
o Procedure for updating the response plan;
Although EPA's required elements for emergency response are essential to any
emergency response program, they are not comprehensive guidelines for creating an
adequate response capability. Rather than establish another set of federal requirements
for an emergency response program, EPA has limited the provision of its rule to those in
the CAA mandates. If a facility has a regulated substance on site, it already is subject to
at least one emergency response rule; OSHA's emergency action plan requirements (29
CFR 1910.38). Under OSHA's HAZWOPER regulations, any facility that handles
"hazardous substances" (a broad term that includes all of the CAA regulated substances
and thus applies to all facilities with covered processes) must comply with either 29 CFR
1910.38(a) or 1910.120(q).
If a facility has a "hazmat" team, it is subject to the 29 CFR 1910.120(q) regulations. If a
facility's emergency response program is developed to comply with the OSHA
requirements and satisfy the elements listed for a "responding facility", generally, no
other action need to be taken to comply with the EPA requirements. The goal is to
create on comprehensive emergency response program that can respond quickly and
effectively to any type of emergency at a particular facility.
General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR
PART 68). EPA-550-B-04-001 April 2004
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Emergency Response
Facilities have the
option to respond to
their own
emergencies or rely
on local HAZMAT
responders
For all Program 2 or
3 facilities, they must
decide on how
emergencies will be
handled
Non-Responding Facilities
All Non-Responding
Facilities:
n Do not need an Emergency
Response Program, if:
Coordination with local
response agencies is
arranged;
A formal notification
procedure is in place to
activate the response
Non-Responding Facilities
Must Coordinate:
n Toxic substances -
must be included in
the Community
Emergency Response
Plan
n Flammables - local fire
department regarding
response procedures
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Non-Responding Facilities
Notification must:
n Establish
appropriate
mechanism to notify
emergency
responders in an
emergency
n Identify an
emergency contact
that the responder
will call for a toxic or
flammable release
Responding Facilities
Emergency Response
Program:
n Written Emergency
Response Plan
n Procedures for using,
inspecting, testing, and
maintaining emergency
response equipment
n Training for employees
n Have procedures to
update the emergency
^'C response plan
Emergency Response Program
Emergency Response Plan:
n Procedures for informing the public and emergency
response agencies about releases
n Documentation of proper first aid and emergency
medical treatment necessary to treat human
exposures
n Procedures and measures for emergency response
after an accidental release
n Complies with other contingency plan regulations or
the Integrated Contingency Plan Guidance
n Coordinated with the Community Emergency
Response Plan
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First Responder Training
Facilities must:
n Comply with OSHA
regulations for HAZWOPER
n If employees of the facility
are members of the
HAZMAT team, they are
subject to additional
HAZWOPER requirements
Emergency Response Triggers
An event or release that:
n Affects ongoing operations
n Requires evacuation of employees or the public
from the area
n Poses or has the potential to pose conditions that
are immediately dangerous to life and health
n Poses a serious threat of fire or explosion
n May cause high levels of exposure to toxic
substances
n Creates uncertainty that the employees can
handle the situation with their regular equipment
and exposure limits have not been exceeded
n Causes a situation to be unclear or information is
lacking to make informed decisions
EPA & OSHA
Requirements
EPA requires that
facilities to have
emergency response
procedures to inform the
public and responders
and have measures in
place to manage an
offsite release of a
hazardous substance.
OSHA requires that
facilities protect their
employees by
evacuation, accounting
for employees and
moving responders into
position to manage a
release.
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OSHA Regulations
Facilities who chose to rely on responders must
have an Emergency Action Plan (29 CFR
1910.120 (q) (1) &29 CFR 1910.38)
Facilities who chose to manage their own
response must have an Emergency Response
Plan (29 CFR 1910.120 (q) (2)) and possibly 29
CFR 1910.156 (fire brigades)
Communication
Most important to
protect employees and
the community
Must be able to
communicate with
emergency responders
regarding safety and
employees and
community regarding
evacuation or
sheltering-in-place
Alarm Systems
Employers must have and
maintain alarm systems
Alarm system must use a
distinctive signal for each
purpose
Capable of being
perceived above all
ambient noise or light
levels
Be distinctive and
recognizable as a signal to
evacuate the work area
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Appendix
RMP Definitions
Acronyms
68.3 Risk Management Program Definitions
For the purposes of this part: 40 CFR part 68, CAA 112(r) Risk Management Program
Accidental release means an unanticipated emission of a regulated substance or other extremely hazardous
substance into the ambient air from a stationary source.
Act means the Clean Air Act as amended (42 U.S.C. 7401 et seq .)
Administrative controls mean written procedural mechanisms used for hazard control.
Administrator means the administrator of the U.S. Environmental Protection Agency.
AlChE/CCPS means the American Institute of Chemical Engineers/Center for Chemical Process Safety.
API means the American Petroleum Institute.
Article means a manufactured item, as defined under 29 CFR 1910.1200(b), that is formed to a specific
shape or design during manufacture, that has end use functions dependent in whole or in part upon the
shape or design during end use, and that does not release or otherwise result in exposure to a regulated
substance under normal conditions of processing and use.
ASME means the American Society of Mechanical Engineers.
CAS means the Chemical Abstracts Service.
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more
regulated substances that presents imminent and substantial endangerment to public health and the
environment.
Classified information means "classified information" as defined in the Classified Information Procedures
Act, 18 U.S.C. App. 3, section 1(a) as "any information or material that has been determined by the United
States Government pursuant to an executive order, statute, or regulation, to require protection against
unauthorized disclosure for reasons of national security."
Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in
temperature, pressure, or both, and remains liquid at standard conditions.
Covered process means a process that has a regulated substance present in more than a threshold quantity
as determined under ง68.115.
Crude oil means any naturally occurring, unrefined petroleum liquid.
Designated agency means the state, local, or Federal agency designated by the state under the provisions
ofง68.215(d).
DOT means the United States Department of Transportation.
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Environmental receptor means natural areas such as national or state parks, forests, or monuments;
officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that
could be exposed at any time to toxic concentrations, radiant heat, or overpressure greater than or equal to
the endpoints provided in ง68.22(a), as a result of an accidental release and that can be identified on local
U. S. Geological Survey maps.
Field gas means gas extracted from a production well before the gas enters a natural gas processing plant.
Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing
operations.
Implementing agency means the state or local agency that obtains delegation for an accidental release
prevention program under subpart E, 40 CFR part 63. The implementing agency may, but is not required to,
be the state or local air permitting agency. If no state or local agency is granted delegation, EPA will be the
implementing agency for that state.
Injury means any effect on a human that results either from direct exposure to toxic concentrations; radiant
heat; or overpressures from accidental releases or from the direct consequences of a vapor cloud explosion
(such as flying glass, debris, and other projectiles) from an accidental release and that requires medical
treatment or hospitalization.
Major change means introduction of a new process, process equipment, or regulated substance, an
alteration of process chemistry that results in any change to safe operating limits, or other alteration that
introduces a new hazard.
Mechanical integrity means the process of ensuring that process equipment is fabricated from the proper
materials of construction and is properly installed, maintained, and replaced to prevent failures and
accidental releases.
Medical treatment means treatment, other than first aid, administered by a physician or registered
professional personnel under standing orders from a physician.
Mitigation or mitigation system means specific activities, technologies, or equipment designed or deployed to
capture or control substances upon loss of containment to minimize exposure of the public or the
environment. Passive mitigation means equipment, devices, or technologies that function without human,
mechanical, or other energy input. Active mitigation means equipment, devices, or technologies that need
human, mechanical, or other energy input to function.
FPA means the National Fire Protection Association.
Natural gas processing plant (gas plant) means any processing site engaged in the extraction of natural gas
liquids from field gas, fractionation of mixed natural gas liquids to natural gas products, or both, classified as
North American Industrial Classification System (NAICS) code 211112 (previously Standard Industrial
Classification (SIC) code 1321).
Offsite means areas beyond the property boundary of the stationary source, and areas within the property
boundary to which the public has routine and unrestricted access during or outside business hours.
OSHA means the U.S. Occupational Safety and Health Administration. Owner or operator means any
person who owns, leases, operates, controls, or supervises a stationary source.
Petroleum refining process unit means a process unit used in an establishment primarily engaged in
petroleum refining as defined in NAICS code 32411 for petroleum refining (formerly SIC code 2911) and
used for the following: Producing transportation fuels (such as gasoline, diesel fuels, and jet fuels), heating
fuels (such as kerosene, fuel gas distillate, and fuel oils), or lubricants; Separating petroleum; or Separating,
cracking, reacting, or reforming intermediate petroleum streams.
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Population means the public.
Process means any activity involving a regulated substance including any use, storage, manufacturing,
handling, or on-site movement of such substances, or combination of these activities. For the purposes of
this definition, any group of vessels that are interconnected, or separate vessels that are located such that a
regulated substance could be involved in a potential release, shall be considered a single process.
Produced water means water extracted from the earth from an oil or natural gas production well, or that is
separated from oil or natural gas after extraction.
Public means any person except employees or contractors at the stationary source.
Public receptor means offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and
office buildings, parks, or recreational areas inhabited or occupied by the public at any time without
restriction by the stationary source where members of the public could be exposed to toxic concentrations,
radiant heat, or overpressure, as a result of an accidental release.
Regulated substance is any substance listed pursuant to section 112(r)(3) of the Clean Air Act as amended,
in ง68.130.
Replacement in kind means a replacement that satisfies the design specifications.
Retail facility means a stationary source at which more than one-half of the income is obtained from direct
sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder
exchange program.
RMP means the risk management plan required under subpart G of this part.
Stationary source means any buildings, structures, equipment, installations, or substance emitting stationary
activities which belong to the same industrial group, which are located on one or more contiguous
properties, which are under the control of the same person (or persons under common control), and from
which an accidental release may occur. The term stationary source does not apply to transportation,
including storage incident to transportation, of any regulated substance or any other extremely hazardous
substance under the provisions of this part. A stationary source includes transportation containers used for
storage not incident to transportation and transportation containers connected to equipment at a stationary
source for loading or unloading. Transportation includes, but is not limited to, transportation subject to
oversight or regulation under 49 CFR parts 192, 193, or 195, or a state natural gas or hazardous liquid
program for which the state has in effect a certification to DOT under 49 U.S.C. section 60105. A stationary
source does not include naturally occurring hydrocarbon reservoirs. Properties shall not be considered
contiguous solely because of a railroad or pipeline right-of-way.
Threshold quantity means the quantity specified for regulated substances pursuant to section 112(r)(5) of
the Clean Air Act as amended, listed in ง68.130 and determined to be present at a stationary source as
specified in ง68.115 of this part.
Typical meteorological conditions means the temperature, wind speed, cloud cover, and atmospheric
stability class, prevailing at the site based on data gathered at or near the site or from a local meteorological
station.
Vessel means any reactor, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose, or other container.
Worsf-case release means the release of the largest quantity of a regulated substance from a vessel or
process line failure that results in the greatest distance to an endpoint defined in ง68.22(a).
[59 FR 4493, Jan. 31, 1994, as amended at 61 FR 31717, June 20, 1996; 63 FR 644, Jan. 6, 1998; 64 FR 979, Jan. 6,
1999; 65 FR 13250, Mar. 13,2000]
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Definitions of Acronyms
AlChE American Institute of Chemical Engineers
ALOHA Arial Locations of Hazardous Atmospheres
ANSI American National Standards Institute
API American Petroleum Institute
ASHRAE American Society of Heating, Refrigerating and Air-Conditioning
Engineers
ASME American Society of Mechanical Engineers
ASTM American Society of Testing Materials
BLEVE Boiling Liquid, Expanding Vapor Explosion
CAA Clean Air Act
CAS Chemical Abstracts Service
CBI Confidential Business Information
CCPS Center for Chemical Process Safety
CEPPO Chemical Preparedness and Prevention Office
CERCLA Comprehensive Environmental Response, Compensation and Liability
Act
CFR Code of Federal Regulations
CSB U.S. Chemical Safety and Hazard Information Board
DOT U.S. Department of Transportation Environmental Protection Agency
EPA U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FMEA Failure Mode and Effects Analysis
FTA Fault Tree Analysis
HAZMAT Hazardous Materials
HAZOP Hazard and Operability Analysis
HAZWOPER Hazardous Waste Operation and Emergency Response
IDLH Immediately Dangerous to Life and Health
MAR International Institute of Ammonia Refrigeration
LEPC Local Emergency Planning Committee
LFL Lower Flammable Limit
MOC Management of Change
MSDS Material Safety Data Sheet
NAICS North American Industrial Classification System
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety and Health
NOAA National Oceanographic and Atmospheric Administration
NRC National Response Center
OSHA Occupational Safety and Health Administration
P&ID Process and Instrumentation Diagram
PFD Process Flow Diagram
PHA Process Hazard Analysis
PSI Process Safety Information
PSM Process Safety Management
PSSR Pre-Startup Safety Review
RMP Risk Management Program
SERC State Emergency Response Commission
SIC Standard Industrial Classification
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