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

DOE-HDBK-1101-96

Comparison of the Proposed 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; Proposed Rule" (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 final 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:

1) Performance of hazard assessments which includes analyses of the "worst case"

accident consequences.

2) Preparation of written risk management plans to document the risk management

program. The plans will be submitted to designated agencies and will be available to

the public.

3) Registration of the risk management plans with the EPA.

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

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

Risk Management Program

Under the proposed rule, a risk management plan must be developed and implemented by all

facilities that manufacture, process, use, store, or handle regulated substances. RMPs are proposed

to provide facilities with 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 is proposing an 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

The proposed rule is designed to assist facilities and communities in efforts to lessen the number and

severity of serious chemical accidents. Under EPA's proposed RMP, facilities must complete a

hazard assessment to evaluate potential effects of an accidental release of any regulated substance

present at or above the threshold quantity. The hazard assessment also must evaluate the impact of

C-1