System Safety for the 21st Century, 2nd Edition

CHAPTER 23EPA’s Equivalent Process Safety Requirements—Risk Management Program (RMP)

While the OSHA rule applies to operations that affect workers within a site where certain highly hazardous chemicals are present at stated levels, the EPA rule was developed to additionally protect the public and the environment from the undesired consequences of explosions and other accidental releases. Much of the information in this chapter comes from DOE‐STD‐l100 (U.S. Department of Energy 1996) and is enhanced with associated material from the System Safety Analysis Handbook (Stephans and Talso 1997) and other sources as specified.

The purpose of this chapter is to describe the requirements of the EPA Risk Management Program (RMP), discuss some of the differences between it and the OSHA PSM rule, and highlight the importance of the rule to the public and the environment.

BACKGROUND

The EPA notes in its general guidance document (U.S. EPA 1998) that the RMP goal is to prevent accidental releases of substances that can cause serious harm to the public and the environment from short‐term exposures and to mitigate the severity of releases that do occur.

One may ask why this EPA rule is needed if there is an OSHA PSM rule? Originally there was a parallel schedule with the OSHA PSM, but due to the tempo of enactment, the two regulations ended up being enacted about four years apart.

By way of an overview introduction, the chapter will provide an overall summary of the RMP, discuss the hazard ...