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Process Safety Management for Highly Hazardous Chemicals - index
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Emergency Response Program - doe-hdbk-1101-20040174


DOE-HDBK-1101-2004
The concentration of the substance when released
Duration of the release
Date and time of the release
Offsite consequence(s) (e.g., evacuations, injuries).
Note that most of the releases that meet the criteria of the proposed EPA RMP are already
reported under CERCLA and SARA Title III. Most of the information needed to define
accidental release scenarios will be derived from the process hazard analysis.
Prevention Program
Along with the hazard assessment and the emergency response program, the risk management
plan includes a prevention program. In addition to the process hazard analysis, the prevention
program covers safety precautions and maintenance, monitoring, and employee training
measures. However, the OSHA PSM rule does include elements which are specific to worker
protection issues that EPA has not included in its rule.
Requirements of the EPA prevention program are similar to the requirements of the OSHA PSM
rule with parallel elements being nearly identical. This similarity exists because EPA separates
the offsite consequence analysis and the five-year accident history from the formal process
hazard analysis requirements.
The integrated approach of the EPA prevention program consists of the following twelve
elements:
Process hazard analysis
Process safety information
Standard operating procedures
Training
Maintenance (mechanical integrity)
Pre-startup review
Management of change
Safety audits
Accident investigation
Employee participation
Hot work permit
Contractors.
EPA's RMP requires that the order in which PrHAs are conducted be prioritized based on offsite
consequences. The qualitative evaluation of safety and health impacts focuses on impacts on
public health and environment rather than impacts on employees. The identification of previous
incidents as a part of the prevention program PrHA emphasizes offsite consequences rather than
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