PT Notes
EPA RMP Rule Amendments - Hazard Review and Process Hazard Analysis
PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.
This PT Note describes amendments to EPA's Risk Management Program regulation relating to address incident investigations in hazard reviews and process hazard analyses that are part of the prevention program. A previous PT Note addressed amendments to PHA requirements that require a Safer Technology and Alternatives Analysis (STAA).
Incident Investigation Findings
EPA has amended the RMP rule to require the owner or operator to consider findings from incident investigations during hazard reviews.
EPA noted that the basic purpose of a hazard review is to identify what process equipment malfunctions or human errors could potentially lead to accidental releases, and then to identify what safeguards are needed in order to prevent such malfunctions and errors from occurring. An obvious source of information about such malfunctions and errors is information gained from investigating incidents that have previously occurred within the covered process.
All available incident information should be reviewed but EPA noted that the rule does not require the owner or operator to retain incident investigation reports for more than five years. However, if the owner or operator has access to incident information beyond that period, EPA believes they should incorporate it into their hazard review, as appropriate.
Also, EPA has amended the RMP rule to require the owner or operator to consider findings from incident investigations, as well as any other potential failure scenarios, during a PHA. Other potential failure scenarios may include those introduced from major process changes or new designs or those discovered as a result of an accident investigation. They may be incidents that occurred at other similar facilities and/or processes, and failure mechanisms discovered in literature or from other sources of information. EPA believes that it is appropriate to research information about other potential scenarios and consider these scenarios when conducting a PHA.
EPA is requiring that the five-year PHA revalidation address the findings from all required incident investigations, as well as any other potential failure scenarios.
The final rule may be found at:
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