Comparison of the EPA Risk Management Program with OSHA's Process Safety Management Program

DOE-HDBK-1101-2004

Comparison of the EPA Risk Management Program with

OSHA's Process Safety Management Program

The Environmental Protection Agency's (EPA) "Risk Management Programs for Chemical

Accidental Release Prevention" (40 CFR Part 68) adds significant new requirements beyond

those in the Occupational Safety and Health Administration (OSHA), "Process Safety

Management of Highly Hazardous Chemicals" (29 CFR 1910.119). In addition, the chemical list

and threshold quantities for the EPA rule differ somewhat from those in the OSHA rule and may

well result in a facility needing to expand their risk management program to other portions of the

facility as shown in Appendix A.

The three principal areas in which the requirements of the EPA exceed those of the OSHA Rule

are:

Performance of hazard assessments which includes analyses of the "worst case" accident

consequences.

Preparation of written risk management plans to document the risk management program.

EPA makes the plans available to the public, State and local emergency planning officials

and the Chemical Safety and Hazard Investigation Board. Response actions have to be

coordinated with local emergency planning and response agencies.

Registration of the risk management plans with the EPA.

The key differences between the OSHA rule on process safety management (PSM) and the EPA

Risk Management Program (RMP) are discussed in the following sections.

Risk Management Program

A risk management plan must be developed and implemented by all facilities that manufacture,

process, use, store, or handle regulated substances to provide an integrated approach to

identifying and managing the hazards posed by the regulated substances. The RMP consists of

three major parts (a) a hazard assessment, (b) a prevention program, and (c) an emergency

response program.

EPA considers critical its requirement for the owner or operator of a facility to define its

management system and name the person or position responsible for the program. The facility

owner or operator also would be required to document the results of the risk management

program(s) in the risk management plan. Facilities will be required to maintain onsite

documentation of the implementation of the risk management plan.

EPA requires a risk management plan that summarizes the program elements because the

information of most use to the public and local agencies will be related to the hazard assessment

and consequence analysis.

Hazard Assessment

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