PT Notes
EPA RMP Rule 2024 Amendments - STAA Practicability Assessment
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.
The amended rule requires that Program 3 Process hazard Analysis address STAA, which involves the application of the hierarchy of controls for process safeguards.
An IST/ISD Practicability Assessment is required for covered processes in
- NAICS codes 324 and 325, located within 1 mile of another stationary source having a covered process in NAICS code 324 or 325.
- NAICS code 324 with hydrofluoric acid alkylation covered processes.
- NAICS codes 324 and 325 that have had one accident that meets the accident history reporting requirements of the RMP rule since the most recent process hazard analysis.
For these covered processes, the facility owner or operator shall:
Determine and document the practicability of the inherently safer technologies and designs considered. The owner or operator shall include in documentation any methods used to determine practicability.
EPA defines practicability as:
The capability of being successfully accomplished within a reasonable time, accounting for environmental, legal, social, technological, and economic factors. Environmental factors would include consideration of potential transferred risks for new risk reduction measures.
EPA believes that the practicability assessment will provide the public and local emergency managers with important context regarding a facility’s consideration of safer technologies and alternatives.
EPA believes that the amended RMP rule will allow the owner or operator to consider the potential for risk reduction, risk transfers, and tradeoffs when determining whether it is practicable to implement ISTs or ISDs considered.
The amended RMP rule is intended to give the facility owner or operator the flexibility to assess and to determine the practicability of any measures considered based on various factors for IST, including those involving risk transference.
EPA is not requiring implementation of identified IST. EPA believes facility owners and operators will adopt IST even in the absence of a mandate when it is practicable technically and economically and when the hazard reduction is significant. Part of the basis for this belief is the likelihood that most of the economic savings resulting from reduced accidents will be from reduced onsite property damage to the owner or operator’s facility.
EPA believes that it is appropriate for a facility to consider the five practicability factors (i.e., environmental, legal, social and, technological, and economic) for evaluating the appropriateness of implementing for potential IST measures because some IST can involve significant costs or involve impacts that go beyond the facility. These factors are recognized and discussed in in CCPS’s, Guidelines for Inherently Safer Chemical Processes, A Life Cycle Approach, 3rd Edition, and the NJDEP’s Guidance for Toxic Catastrophe Prevention Act (TCPA), Inherently Safer Technology (IST) Review, Attachment 1, Feasibility Guidance.
EPA expects that facilities will only evaluate chemical substitutes that have already been shown to be commercially viable and does not expect facility owners or operators to expend a major effort on hypothetical or untested chemical substitutes or uses.
EPA believes that while the greatest potential opportunities for using IST may exist early in process design and development, many IST options may still be practicable after the initial design phase. Furthermore, STAA involves more than just IST. Safer technology alternatives also include passive measures, active measures, and procedural measures, and these measures can be modified and improved after the initial design of a facility. EPA notes that while many RMP-regulated facilities were originally constructed decades ago, major enhancements have been reported in some plants that have been operating for many years. Moreover, to the extent that particular measures are cost-prohibitive, the rule allows for that to be a factor in assessing whether a measure is practicable.
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Disclaimer: This PT Note provides Primatech’s interpretation of regulatory requirements. The actual regulatory requirements can be found at: https://www.epa.gov/rmp
