Update to the EPA RMP Rule. Part 5: Root Cause Analysis
This is the fifth post in our series in which we review the proposed updates to the EPA’s (U.S. Environmental Protection Agency) Risk Management Program (RMP). This series complements the similar series for OSHA’s Process Safety Management (PSM) standard. The update process for the EPA rule is described in the post The EPA RMP Updates. As time permits, we will review and analyze each of the EPA’s proposed changes. We will also compare them with the comparable OSHA update — where one exists. An index of the updates so far is provided here.
The proposed change that we consider in this post is to do with root cause analysis. (All comments refer to Scope 3 requirements.)
Prevention Program (Subparts C and D) Root Cause Analysis
Requiring a formal root cause analysis incident investigation when facilities have had an RMP-reportable accident.
OSHA has a similar proposal with respect to root cause analysis. Our review of that requirement is provided at Update to OSHA’s Process Safety Management Regulation. Part 23: Root Cause Analysis. In that post we discussed some of the difficulties and concerns with a requirement to conduct root cause analysis. Indeed, it is worth repeating the Nelms quotation.
An 800 person forum comprised of Root Cause Analysis (RCA) practitioners from all over the world tried to define “Root Cause Analysis.” They could not agree on an answer. . . . It means different things to different industries – even different things within the same industries. It is even difficult to find consistency within the same companies, or even sites within a company.
EPA Fact Sheet
In their Fact Sheet, The Importance of Root Cause Analysis During Incident Investigation, OSHA and the EPA say,
A successful root cause analysis identifies all root causes—there are often more than one.
This statement is misleading — there is always more than one cause of an incident, but none of them are a true “root cause”.
It will be interesting to see if either OSHA or the EPA provide further clarification as to what they mean by the term ‘root cause analysis’.