Process Safety Management and Risk Management Program (PSM/RMP) Audits: Are You Prepared?

In June 1996, the Environmental Protection Agency (EPA) promulgated 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (RMP) Under Clean Air Act, Section 112 r (7), commonly called the RMP rule. Much of the RMP rule was already required by the Occupational Safety and Health Administration’s (OSHA) 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals (the PSM Standard), which had been issued four years earlier. Because both of these regulations include anhydrous ammonia at a threshold level of 10,000 lbs., many refrigerated warehousing and manufacturing facilities are subject to them. Since the two regulations have the same threshold quantity for ammonia, facilities that are subject to RMP are also subject to PSM. While the focus of the two regulations differs, there are many common requirements, as shown in Table 1, Comparison of Process Safety Management and Risk Management Program Requirements. Both rules require the development of extensive accident prevention programs, which include Process Hazard Analyses, operation and maintenance procedures, training, and emergency response plans. The RMP rule also requires Offsite Consequence Analyses and a Plan summary submittal to the EPA before a process starts up and at five-year intervals thereafter. The Program 3 Prevention Program required to satisfy RMP, is almost identical to a PSM program. Most subject facilities, therefore, use their PSM Program to serve as their RMP Prevention Program. In Florida, the Department of Community Affairs (DCA) took delegation of the RMP rule from the EPA and is the enforcing agency in this state. Since the summer of 2000, the DCA has been auditing RMP facilities for compliance with the rule, and their list of audit subjects has included several citrus manufacturing facilities. The DCA staff has been performing very thorough audits, looking closely at all of the RMP Prevention Program, or PSM Program, elements and evaluating their implementation status at each site. The DCA typically cites RMP Prevention Program deficiencies in the following areas: Mechanical Integrity, Standard Operating Procedures, Process Hazard Analysis, training records, incident investigation reporting, compliance audits, and emergency response planning. Although Florida does not have a State-OSHA program, the DCA is, effectively, serving in this function as they audit the PSM programs of refrigerated facilities throughout the state. Facility owners should therefore ensure that their PSM/RMP Prevention Programs are well developed and well implemented prior to a DCA audit. Paper published with permission.