Prevention Program - hdbk11010169

DOE-HDBK-1101-96

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 proposed 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 is proposing to

separate the offsite consequence analysis and the five-year accident history from the formal process

hazard analysis requirements.

The proposed integrated approach of the EPA prevention program consists of the following nine

elements. These elements adopt and build on the OSHA PSM program elements:

Process hazard analysis

Process safety information

Standard operating procedures

Training

Maintenance (mechanical integrity)

Pre-startup review

Management of change

Safety audits

Accident investigation.

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 is limited to those with offsite consequences rather than

those with catastrophic consequences in the workplace as required by the PSM Rule. Facilities are

expected to have fewer incidents to consider under the EPA RMP Rule, because some potential

incidents will not have offsite impacts.

Another EPA requirement, which is not included in the OSHA PSM rule, is that a facility define its

management system. Facilities are required to identify the person (by name) or the position

responsible for implementing the prevention program.

In addition, the prevention program and the OSHA PSM program have different implementation

schedules under process hazard analysis. Facilities are required to comply with the EPA's RMP

Rule within three years of the date of the promulgation. OSHA's process hazard analysis

implementation schedule is five years.

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