ACKNOWLEDGEMENT

The success of the 16th Annual Meeting of the International Institute of Ammonia Refrigeration is.due to the work of the authors whose technical papers appear in this book.

IlAR expresses its deepest appreciation t o these authors for their contributions to the betterment of the industry and to the following individuals for their collaborative efforts in editing these papers:

Wilbert F. Stoecker, IIAR Scientific Advisor Julia A. Janko, IIAR Project Coordinator Janet Land ; Technical Writer-Editor

-- IlAR Board

NOTICE

The views expressed in the papers contained in this book are those of the individual authors. They do not constitute the official views of IlAR and are not endorsed by it.

Washington, D.C. Tel: 202/857-1110 Fax: 202/223-4579

I

I I I I 1 I I I I I I 1 I I I I I I I

EPA'S RISK MANAGEMENT PLAN REQUIREMENTS

By:

Peter R. Jordan

Neil P. Mulvey

Primatech Inc.

Princeton, New Jersey

Presented at:

IlAR 16th Annual Meeting

March 6-9, 1994

St. Louis, Missouri

I I 1 I I I I I I 1 I I I 1 I I I I I

1. INTRODUCTION

For the past t w o years, companies that own and operate ammonia refrigeration

systems have been developing and implementing programs and procedures to

comply with the Occupational Safety and Health Administration (OSHA) Process

Safety Management (PSM) regulations (1). On October 20, 1993, the U.S.

Environmental Protection Agency (EPA) published their long anticipated proposed

regulations for Risk Management Programs for Chemical Accidental Release

Prevention (2).

On the whole, the proposed EPA requirements are very similar t o the existing

OSHA PSM regulations. However, the differences between the regulations are

quite significant. Key differences include the need t o conduct dispersion and

consequence analysis and to make Risk Management Plans (RMPs) publicly

available.

This paper will describe the differences between the t w o process safety

regulations, review the new EPA requirements in detail, and provide guidance on

what ammonia refrigeration companies can do to prepare for EPA’s RMP

requirements.

Peter R. Jordan is Senior Principal Engineer and Neil P. Mulvey is Senior Vice

President of Primatech Inc. in Princeton, New Jersey.

47

II.

On

BACKGROUND

February 24, 1992, the U.S. Occupational Health and Safety Administration

(OSHA) dramatically changed the way many companies operate and manage their

facilities. OSHA promulgated a new and far reaching regulation known as Process

Safetv Management of Hiqhlv Hazardous Chemicals, 29 CFR 191 0.1 1 9 (1 ). The

regulations apply t o any facility handling in excess of the threshold quantity of a

listed highly hazardous chemical, or 10,000 pounds or more of a flammable liquid

or gas. The regulation applies to all refrigeration systems handling 10,000 pounds

or more of anhydrous ammonia. An estimated 42,500 ammonia refrigeration

facilities may be covered by the standard. Today the regulations are in full force

and companies are required t o comply with the standard.

OSHA's Process Safety Management (PSM) standard identifies requirements for

preventing or minimizing the consequences of major uncontrolled releases, fires, or

explosions that may present a serious danger to employees in the workplace.

Over the past t w o years, ammonia refrigeration facilities have worked toward

achieving compliance with the PSM standard by developing and implementing a

PSM program. In many cases, approaches to compliance have started with a full-

scale PSM audit designed to establish a benchmark, and provide a foundation and

direction for companies to build upon. Some facilities have retained consultants

with expertise in PSM to assist in the development of a PSM program. In other

cases, companies have decided t o develop the necessary programs using in-house

resources. Still, in other cases, companies have chosen t o develop a model or

"generic" program from which to build upon. In fact, the International Institute of

Ammonia Refrigeration's (IIAR) Process Safety Management Task Force has

developed a series of guideline documents entitled "Guide t o the Implementation of

Process Safety Management for Ammonia Refrigeration" (3). This guideline

package is intended t o assist facilities in developing PSM programs.

I I I I I I I 1 I 1 I I I 1 I I I 1 1 4%

On October 20, 1993, the US Environmental Protection Agency (EPA) published

their long anticipated proposed regulations for Risk Manaqement Proqrams for

Chemical Accidental Release Prevention, 40 CFR Part 68 (2). Like OSHA's PSM

standard, EPA's requirements are designed to prevent or minimize the

consequences of major uncontrolled releases, fires, and explosions. The key

difference, however, is that while the PSM standard is designed t o protect

employees, the EPA requirements are designed to protect public health and the

environment. This important distinction in the intent of the t w o regulations is a

major factor in the new and far reaching RMP requirements, over and above those

identified in the PSM standard.

On the whole the proposed EPA requirements are very similar to the existing OSHA

PSM regulations. However, the differences between the regulations are quite

significant. EPA's mandate to protect public health and the environment places

heavy emphasis on identifying and evaluating the offsite consequences of

accidental releases. Additionally, in keeping with EPA's mission of information

dissemination and risk communication established by the Community Right-to-

Know (CRTK) and Emergency Response Planning requirements under Title Ill of the

Superfund Amendments and Reauthorization Act (SARA) of 1986, the new

proposed EPA requirements include public access to facilities' risk management

programs. This and other important requirements of the EPA program are

described below.

111. OSHA's PSM STANDARD

The OSHA regulation presents performance based standards for preventing or

minimizing major accidents which have the potential to cause serious danger t o

employees. The OSHA PSM standard includes the following fourteen elements:

Employee participation

Process safety information

Process hazard analysis

Operating procedures

49

0

0

0

0

0

0

0

0

0

0

Training

Contractors

Pre-startup safety review

Mechanical integrity

Hot work permit

Management of change

Incident investigation

Emergency planning and response

Compliance audits

Trade Secrets

While the PSM standard includes specific requirements, it is generally written in

broad language that has been subject t o a significant amount of interpretation.

Compliance schemes for chemical and petroleum companies do not necessarily

work for ammonia refrigeration facilities.

Ammonia refrigeration facilities have struggled to comply with the process hazard

analysis (PHA), employee participation, process safety information, and operating

procedure requirements of the PSM standard.

IV. EPA'S PROPOSED RMP REQUIREMENTS

EPA's new RMP requirements began with a proposed list of regulated substances

and threshold quantities for toxic, flammable, and explosive substances. This

proposed list was published on January 19, 1993 (4). The list is expected t o be

finalized in early 1994. EPA estimates that over 140,000 facilities will be covered

by the proposed list, including 50,000 cold storage facilities. The proposed

threshold quantity for anhydrous ammonia was 1,000 pounds.

The proposed RMP requirements can be organized into the following general

categories:

50

I I 1 I 1 I I I I I I I I I 1 I I I I

Registration

Hazard assessment

0 Prevention program requirements

Emergency response program

0 Risk management plan

An overview of the requirements in each of these categories is described below.

A. Registration

The proposed rule specifies that facilities are required to register with EPA

within three years after a final rule is issued, if they have a regulated substance

(anhydrous ammonia) in a quantity that exceeds the threshold quantity

(proposed as 1,000 Ibs). The registration would consist of a form to be sent t o

EPA headquarters as part of the Risk Management Plan (RMP) indicating that

the facility is covered by the rule, identifying the substances triggering the

registration and the quantity of the substance in the process. There are three

primary reasons that EPA has proposed the registration requirement.

Clean Air Act Amendments of 1990 (CAAA) requires that RMPs be registered

with EPA. Second, EPA will use the registrations t o establish a system for

auditing RMPs. Finally, the registration would provide a current source of data

which identifies all facilities likely to be covered by the proposed rule.

First, the

EPA is currently proposing a simple registration that would require most

ammonia refrigeration facilities to complete a one-page form. The registration

form would include:

the name, address, and telephone of the facility;

the facility's Dun and Bradstreet number;

the names and CAS numbers of all regulated substances on site;

the maximum amount present of the regulated substances at any one time (in ranges);

51

0 the facility’s Standard Industrial Classification (SIC) code(s) that apply t o the use of each substance;

0 the name of the contact person; and,

a certification by the owner or operator that, to the best of the signer’s knowledge, the information submitted is true, accurate, and complete.

Note that most of the information requested is already reported under SARA

Title Ill. For example, the reporting ranges proposed are the same ranges used

for SARA Title Ill reporting.

In order t o reduce the time needed to enter and process the registration form,

EPA is considering developing computerized software that would allow

electronic filing of the information. The computerized form would provide

facilities with a quick check on the accuracy of their information and assure

them that the data would be accurately represented in EPA‘s database.

If any information in the registration becomes inaccurate after the registration

form is submitted, the facility would be required t o file an amended registration

t o EPA and the state/local implementing agency within 60 days.

B. Hazard Assessment

The CAAA requires that facilities perform a hazard assessment for each

regulated substance present above the threshold quantity. The purpose of the

hazard assessment is to evaluate the impact of significant accidental releases

on public health and the environment, and t o develop a history of such

releases. The hazard assessment is separate from the formal process hazard

analysis requirement.

The hazard assessment contained in the proposed rule would require facilities

to:

0 determine the worst-case accidental release scenario for the regulated substance;

52

I I I I 1 I 1 I I 1 I I I I I I D I I

identify other more likely significant accidental releases for each process;

analyze offsite consequences for the identified release scenarios including the worst case scenario; and,

document a five-year history of significant accidental releases which had, or had the potential for, offsite consequences. The history should list the release date, time, substance and quantity released, duration of the release, concentration of the substance released, and any offsite consequences.

The proposed definition of worst-case release is the instantaneous loss of all of

the regulated substance in a process, with failure of all mitigation systems

(active and passive). The range of more likely release scenarios should include

only those events that could lead t o "significant" releases. EPA has defined

significant releases as accidental releases that have the potential t o cause

offsite death, injury, or serious adverse effects t o human health or the

environment. The proposed rule specifies several possible accident causes that

facilities should consider when defining release scenarios. These causes

include failure of transfer hoses, process piping, and process vessels.

Facilities that use the regulated substances above its threshold in several

locations (for example, t w o separate ammonia refrigeration systems on the

same site) would need to evaluate a range of accidental releases and determine

a worst-case release scenario for each location.

Once the worst-case and more likely significant release scenarios are identified,

the facility would be required t o analyze the offsite consequences. The offsite

analyses would estimate, using dispersion models or other approaches, the

possible rate of release, quantity released, duration of the release, and the

distances in any direction that the substance could travel before it is dispersed

enough t o no longer pose a threat t o the public health or t o the environment.

The releases should be analyzed using average weather conditions and worst-

case weather conditions. Worst-case weather conditions are defined as a wind

53

EPA has published guidance on conducting similar analyses in i ts Technical

Guidance for Hazard Analvsis (5), and plans to develop additional guidance t o

assist facilities in analyzing offsite impacts. For example, EPA is considering

developing a set of simple, generic tools that could be used for the assessment

of offsite impacts. The advantages of the generic tools would be that the

generic methodology would allow a more direct comparison among facilities

and would also reduce the resources (and costs) which a facility would incur t o

conduct the analysis.

Facilities must document the results of the hazard assessment and the analysis

of offsite consequences. In addition, the hazard assessment must be reviewed

and updated at least once every five years. The facility must complete a new

or revised hazard assessment within 60 days of a change, if changes in the

process, management, or any other relevant aspect of the source or its

surroundings occur which might make the results of the hazard assessment

inaccurate.

C. Prevention Program

EPA’s proposed prevention program requirements parallel those of OSHA’s

PSM standard. The purpose of the prevention program is t o require covered

facilities to develop and implement an integrated management system t o

evaluate the hazards present at the facility, t o find the best way to control

these hazards, and to prevent accidental releases associated with these

hazards. The program covers nine procedural areas as well as requiring a

54

speed of 1.5 meters per second and Class F stability. The offsite analysis

would also identify all populations that could be affected by a release, including

sensitive population areas such as schools and hospitals. In addition, the

analysis would detail potential environmental damage including consideration of

sensitive ecosystems, migration routes, vulnerable natural areas, and critical

habitats.

I I I I I 1 i I I I I I 1 I I I

I I 1 I I I I I I I I I 1 I I I I I I

management system to integrate them. The nine procedural areas are:

Process hazard analysis

Process safety information

0 Standard operating procedures (SOPS)

0 Training

Maintenance

Pre-startup review

Management of change

Safety audits

Accident investigation

A major difference between the EPA's proposed prevention program

requirements and OSHA's PSM standard is the requirement t o develop a

management system.

The purpose of the management system requirement is to ensure that facilities

develop a management system to oversee the implementation of the risk

management program elements. The management system should ensure that

the elements of the risk management program are integrated and implemented

on an ongoing basis and that the responsibility for the overall program and for

each element is clear. As part of the management system, the facility should

designate a single person or position who is responsible for the development

and implementation of the overall program. A t facilities where individual

elements of the program are handled by different people or divisions, the

names or positions of the people responsible for each element should also be

specified.

D. Emergency Response Program

The emergency response planning requirements of the RMP rule enhance and

support existing requirements in OSHA regulations, SARA Title Ill, and other

environmental regulations. For example, the RMP requirements for emergency

55

response planning include:

I I I I I I I 1 I 1

evacuation routes for employees not involved in responding t o the release;

procedures for employees responding t o the release, including protective equipment;

description of all response and mitigation technologies available;

procedures for informing the public and emergency response agencies about releases;

written procedures for the use of emergency response equipment and for inspection, testing, and maintenance of emergency response equipment;

documentation of appropriate first aid and emergency medical treatment for exposure to regulated substances;

training of emergency response personnel in relevant emergency response procedures;

drills and/or exercises to test the plan and evaluate its effectiveness; and,

coordination of the emergency response plan with the local emergency response plans developed by the local emergency planning committees and local emergency response agencies.

E. Risk Management Plan

A facility covered by the proposed rule must prepare a Risk Management Plan

(RMP) which will be submitted t o the state/local implementing agency, the

Chemical Safety and Hazard Investigation Board (CSHIB), the State Emergency

Response Commission (SERC), the Local Emergency Planning Committee

(LEPC), and be made available to the public. The purpose of the plan is two-

fold:

0 To provide government agencies and the public with sufficient information to understand the hazards at the facility and the approach the facility is using t o manage the risks; and,

To have the facility develop an ongoing system for managing implementation of safety practices and procedures.

0

The information included in the RMP will assist government agencies in

assessing the quality and thoroughness of a facility's risk management

program.

I I I I I I I 1 I 56

I 1 1 I I I 1 I t 1 I I I I I 1 I I I

The plan will include:

A copy of the site registration form, with updated information t o ensure that the registration information is accurate;

For each regulated substance, a summary of the hazard assessment, the analysis of off-site consequences, and accident history data;

A description of the major hazards identified through the process hazard analysis (e.g., equipment failures, human errors, natural phenomena, or other factors which could lead t o a significant accidental releases), a description of the consequences associated with each major hazard, a summary of all actions taken or planned t o address these hazards, and how significant accidental releases are prevented or mitigated, or the consequences reduced by these actions. The purpose of the summary is t o identify major hazards and provide an overview of the prevention program being implemented to prevent significant accidental releases;

A summary of the site's emergency response plan; and,

A description of the facility's integrated management system developed t o implement and coordinate the elements of the hazard assessment, prevention program, and emergency response program at the facility.

The plan will include a certification by the owner or operator that, t o the best

of the signer's knowledge, information and belief, that the information

submitted is true, accurate, and complete. The report shall be reviewed and

updated at least every five years and resubmitted t o the implementing agency

and copies submitted t o the CSHIB, the SERC, and the LEPC. If a change

occurs that requires a revised or updated process hazard assessment or process

hazard analysis, then the report shall be updated and resubmitted within six

months of the introduction of the new process or substance.

V. COMPARISON OF OSHA PSM STANDARD AND EPA RMP RULE

The differences between the EPA proposed rule and the OSHA PSM standard are

based on different statutory requirements of the t w o regulations. EPA is required

t o include several elements in its regulation beyond those required by the PSM

standard.

included in the RMP rule. Table 1 describes the differences between the PSM

standard and the RMP rule.

Conversely, the PSM standard contains several elements that are not

57

VI. GUIDANCE ON PREPARING FOR EPA'S RMP REQUIREMENTS

While the majority of the proposed RMP requirements are quite similar to the PSM

regulations, particularly the prevention program requirements, there are clearly

some significant differences that ammonia refrigeration facilities can begin t o plan

for. The following thoughts apply to those ammonia refrigeration facilities that

either have a fully developed OSHA PSM program, or are in the process of

developing and implementing a PSM program. Facilities that are not covered by

the OSHA standard and have no developed PSM program will, of course, need t o

develop all of the necessary programs and procedures.

The requirement t o complete and submit a registration form does not require any

pre-planning, but it does require a realization by facility owners and operators that

their facility will be identified as one that handles a toxic substance(s) as defined

by the EPA. The PSM standard has no similar requirement to "stand-up and be-

noticed", so facilities should prepare for potential inquiries from the general public.

Facilities that are planning to conduct their PHAs should consider expanding the

purpose and objectives of the analysis to meet both the OSHA PSM guidelines and

the proposed EPA requirements simultaneously. When conducting a process

hazard analysis t o meet both guidelines, the objective should be to identify possible

deviations from process design, maintenance, inspection, or operating practices

which could lead to personnel injury, equipment damage, or environmental impact.

Potential hazards which should be emphasized during the analysis are those

involving accidental ammonia releases to the workplace or those which have the

potential for significant offsite consequences.

A hazard analysis typically considers four major types of causes of potential

deviations:

Equipment failures;

Human errors;

External events; and,

I I I I I I I 1 I 1 I I I I I I I 1 I 58

I I I I I I I I I I I I I I I 1 I I I

0 Failure of existing safeguards.

Analysis of these deviations should include:

A qualitative evaluation of the potential hazards and consequences of the deviations on the employees in the workplace and on public health and the environment;

The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace or the potential for significant offsite consequences;

An assessment of the existing engineering and administrative controls (safeguards), including ammonia release prevention and detection methods; and,

An identification of preliminary recommendations, either equipment or procedural, designed t o mitigate or minimize of the consequences or probability of occurrence of accidental ammonia releases.

In practice, very little additional planning will be required to incorporate the OSHA

and EPA requirements during a PHA study. When conducting a PHA for an

ammonia refrigeration facility, the primary purpose should be (and probably always

has been) t o identify any credible scenario which could lead t o any accidental

ammonia release regardless of the size or the duration of the release. There must

be a certain awareness both during study preparation and during the study itself t o

ensure that offsite consequences of these releases are properly addressed. The

study time required t o complete the analysis should not be significantly affected.

This paper does not provide details on how to conduct the required hazard

assessment, however, there are some steps which facilities should consider taking

to prepare for the upcoming hazard assessments. First, facilities should decide

who will be conducting the hazard assessments. The primary choice will be

whether t o develop in-house expertise to conduct the assessments or t o utilize the

services of an outside consultant. Note that even if the EPA does develop generic

tools which can be used t o conduct the hazard assessment for ammonia

refrigeration facilities, it will be difficult (if not impossible) t o construct a generic

model which includes all the assumption necessary to complete the assessment.

59

Therefore, a certain amount of expertise will be needed t o select appropriate

release scenarios for inclusion in the assessment, t o estimate the amount of

ammonia which can be released, to determine which dispersion model should be

used t o analyze the offsite consequences of the release scenarios, and t o interpret

the assessment to provide meaningful, useful results.

Second, facilities should develop a database which includes a five-year history of

significant accidental releases which had, or had the potential for, offsite

consequences. The history should list the release date, time, substance and

quantity released, duration of the release, concentration of the substance released,

and any off-site consequences. This database would be used to choose potential

release scenarios for inclusion in the hazard assessment.

Third, facilities should gather appropriate source siting data which can be used

during the process hazard analysis and during the hazard assessment. This data

should include:

Meteorological data which can be used t o assess average atmospheric conditions near the site. Meteorological data is typically collected at a nearby airport, and is available through the National Weather Service.

The location of nearby populations which could potentially be exposed t o accidental ammonia releases. Special emphasis should be placed on identifying sensitive population areas such as schools and hospitals. This data is typically contained on U.S. Geographical Survey (USGS) topographical maps (typically available at a local library) and from discussions with the local emergency planning committees.

The location of sensitive ecosystems, migration routes, vulnerable natural areas, and critical habitats for threatened or endangered species. This data is typically included in USGS maps or in local planning documents.

Finally, facilities should consider meeting with the implementing agency (i.e., state

environmental agency) or the LEPC t o determine how the results of the hazard

assessment will be utilized. The ultimate use of the assessment will affect h o w

the assessment is conducted, and a preliminary meeting can be used t o establish

guidelines t o conduct the assessment.

60

I 1 1 1 I I I I I 1 I I I 1 I I I 1 I

I 1 I I I I I I i I i

I I 1 I

I I

a

a

The contents of a facility's RMP will be publicly available, via the LEPC, the SERC,

or the state implementing agency. For the first time, community representatives

and local agencies will have access to details regarding the potential hazards within

operating facilities. This information will include details on the worst-case release

scenarios and the potential consequences of those releases. The best way a

facility can begin to prepare for the release of this information is t o establish

outreach programs with community members. Outreach efforts can include:

0

community open houses and facility tours

joint emergency response training activities and exercises

participation in the planning activities of the LEPC

participation in other community activities

The public will likely react more

comfortable and knowledgeable

facility.

rationally to the RMP information if they are

with the operations and management within the

VII. CONCLUSIONS

OSHA's PSM standard has had a significant impact on the management and

operation of ammonia refrigeration facilities. EPA's proposed RMP requirements

will go yet one step further than the PSM regulations by requiring the identification

of worst-case release scenarios, the analysis of offsite consequences, and the

public availability of risk management information.

Where applicable, ammonia refrigeration facilities should continue to develop and

implement their PSM program t o meet OSHA's PSM standard. This effort should

be a top priority since these regulations are already in place. OSHA is conducting

inspections and facilities are subject to fines for non-compliance.

The EPA regulation is in draft form as a proposal, and is subject t o change. It is

reasonable to expect that the EPA regulations will not be finalized until late 1994.

In addition, the proposal allows three years for facilities t o develop their RMP and

61

t o come into compliance.

Facilities can prepare, however, for the EPA requirements by:

ensuring that PHAs aadress offsite consequences;

developing a formal management plan; which might involve simply a formalization of existing policies and procedures;

minor editorial and content modifications t o the PSM procedural elements t o ensure that they comply with the proposed EPA regulations;

planning for the conduct of a hazard assessment; and,

initiating community outreach activities.

Facilities should continue to focus on OSHA's PSM standard, but advanced activity

on the proposed EPA RMP requirements will help t o reduce the cost and effort of

compliance when the proposed regulations are finalized.

62

1 I I I I I I I I 1 I I I I I I i 1 I

I I I 1 I I I I I I I I I 1 1 I I I I

REFERENCES

USOSHA. "Process Safety Management of Highly Hazardous Chemicals; Explosive and Blasting Agents; Final Rule," 29 CFR 191 0.1 19. U.S. Department of Labor: Occupational Safety and Health Administration, February 1992.

USEPA. "Risk Management Programs for Chemical Accidental Release Prevention; Proposed Rule," 40 CFR Part 68. U.S. Environmental Protection Agency, October 1993.

IIAR. Guide t o the Implementation of Process Safetv Manaqement (PSM) for Ammonia Refrineration. International Institute of Ammonia Refrigeration.

USEPA. "List of Regulated Substances and Thresholds for Accidental Release Prevention; Proposed Rule", 40 CFR Part 68. U.S. Environmental Protection Agency, January 1993.

USEPA. Technical Guidelines for Hazard Analvsis.

63

TABLE 1

Comparison of EPA and OSHA Process Safety Regulations

Chanaes from OSHA PSM Standard ~ ~~~

( 1 1 the priority for conducting the analysis would consider offsite consequences rather than the number of potentially affected employees

(2) EPA has a three year implementation rather than five year schedule

(3) previous incidents are limited to those with offsite consequences rather than only to employees

(4) qualitative evaluation of safety and health impacts concentrates on public health and the environment rather than employee safety

(5) requires the evaluation of a plan for, or rationale for not, installing monitors, detectors, containment or control devices, and mitigation systems

requires that the evaluation of the consequences of process deviations include those affecting public health and the environment rather than employees

minor editorial changes only

requires that facilities evaluate the effectiveness of their training programs and revise the programs, if necessary, based on the evaluation

(1 ) referred to as "maintenance" requirements in the EPA proposed rule rather than "mechanical integrity". Requires the facility to develop a list of equipment that requires maintenance, based on PHAs or operating experience

(2) adds the word "maintenance" before inspection and testing throughout the paragraph to clarify that equipment should be maintained on a regular basis

(3) clarifies that training of maintenance workers would be documented as for other training

64

1 I 1 1 i I 1 1 1 1 1

1 1 I I I 1 1

a

I I I I I I 1 I I I I I 1 I I 1 I 1 I

OSHA PSM Element

~~ ~ _ _ _ _ ~ ~

Management of Change

Auditing

Incident Investigation

Contractors

Trade Secrets

Employee Participation

~~~~~

Chanaes from OSHA PSM Standard

(1) requires that maintenance as well as operating employees are trained prior to startup

(2) requires that all employees are trained on any new emergency response procedures ~ ~~ ~

EPA adds a paragraph defining alterations that do not constitute a change. Specifically, "replacement is not a change if the design, materials of construction, and parameters for flow, pressure, and temperature satisfy the design specifications of the device replaced"

~~~ ~~

the safety audit should include an examination of the management systems. The facility can consider the complexity of the process and of the PSM program to develop the safety audit procedures, plans, and timing

(1) referred to as "accident" investigation rather than "incident" investigation

(2) EPA explicitly requires that the accident investigation procedures are written

(3) accidents that require investigation are those that caused or could have caused offsite consequences rather than catastrophic releases in the workplace

(4) investigation has to include the identification of initiatina event and root causes

( 1 ) requires that facilities develop more extensive emergency response plans that detail how to respond to a release to limit offsite consequences

(2) requires coordination with LEPCs

(3) requires periodic drills and emergency response exercises

not included in EPA rule ~~

not included in EPA rule

not included in EPA rule ~~~ ~~

not included in EPA rule

65