Risk Management Plans / 

Process Safety Management 

 

The Union Carbide chemical disaster at Bhopal India

in  1987 changed the way in which people looked at

dangerous industrial chemicals.

 

California and New Jersey were first states in the country to regulate the use of acutely or extremely hazardous chemicals.  California creating Risk Management Prevention Plans through AB 3777 in 1986. Congress then amended the Clean Air Act in 1990 calling for somewhat similar regulation.  This occurred in June 1996 with the publication of a Risk Management Program (RMP) for Chemical Accidental Release Prevention. OSHA was also tasked with a similar objective in 1992 and created Process Safety Management (PSM).  

 

The West Texas fertilizer plant explosion and the California Chevron refinery fire/release in 2012 changed the regulatory environment again with CalEPA creating a Program 4 RMP and Cal / OSHA creating a new regulation for refineries starting October 2017.  Cal / OSHA also split its PSM Unit into two groups: refineries and other chemicals. 

 

In general, RMP and PSM regulations require each facility that stores and/or uses regulated chemicals to create and periodically update:

• A hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases scenarios; 

• A prevention program that includes safety precautions and maintenance, monitoring, and employee training measures; and 

• An emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g., the fire department) should an accident occur.

 

These regulations were written with the intent of including all facilities with flammable and toxic chemicals in a single set of regulations.  This means that the regulations are performance based and are measured against Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).  RAGAGEPs are industry accepted standard practices codified by industry groups such as: the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), the Petroleum Institute, the International Institute of Ammonia Refrigeration (IIAR), the Chlorine Institute, the Compressed Gas Association (CGA), etc.  While these RAGAGEP practices are not regulations, they carry the weight of regulation in the EPA and OSHA code. They are increasingly being enforced as such.

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WHAT DOES THIS MEAN TO YOU?

 

Since multiple agencies are involved, these regulations have created multiple programs with similar intent that require somewhat different reporting requirements for the Federal and California EPA and for OSHA - Cal / OSHA.  In other words, you, the facility operator, are subject to different reporting requirements depending on the organization regulating you.  

 

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In essence, these requirements mean two things:  

• Someone has to create these programs and update them as necessary.

• The required documentation patterns need to be developed in a way that works with the facility’s work flow or it will not get done.

Most facilities do not have full time personnel devoted to these regulations.  They usually assume that someone will perform this work in addition to the full-time job that they are performing.

 

 Developing documentation that works for a facility rather than cutting and pasting a set of forms to check a regulatory box is important when an inspection shows up.  It is also important in developing a consistent safety culture that protects employees and employers alike. EPS takes pride in being a small firm that is specialized in your processes and needs and will develop processes specific to you. We not only understand 

 

We invite you to contact us in order to understand how we can assist you both in terms of program creation and program maintenance to provide a you with a safer cost-effective environment