Update to the EPA RMP Rule. Part 6: Root Cause Analysis

The original post for this topic is located here.

We continue with our reviews of the EPA’s proposed updates to its Risk Management Program. This is the sixth post in this series. Earlier posts are indexed here. The proposed change discussed in this post is to do with audits. (All comments refer to Scope 3 requirements.)

Prevention Program (Subparts C and D) Third-Party Audits

Third-party compliance audits: (1) Requiring the next scheduled compliance audit be a third-party audit when an RMP-regulated facility experiences: (a) two RMP-reportable accidents within five years, or (b) one RMP-reportable accident within five years by a facility with a Program 3 process classified under NAICS code 324 or 325 within one mile of another RMP regulated facility that also has a process classified under NAICS code 324 or 325. (2) Requiring a justification in the Risk Management Plan when third-party compliance audit recommendations are not adopted.

(The term NAICS is explained in the post to do with Safer Technologies.)

OSHA Update

The corresponding OSHA proposed change is Update to OSHA’s Process Safety Management Regulation. Part 25: Third-Party Compliance Audits. As usual, the OSHA requirements are much briefer than those from the EPA. OSHA does not specify that third party audits should be conducted for special cases — as the proposed change stands, they seem to be calling for third-party audits in all situations.

The EPA Proposed Update

The EPA is calling for third-party audits in those cases where a company has had reportable accidents. The agency does not provide detail as to how a third-party audit is to be organized or conducted. They do not specify what qualifications or experience a company or person needs in order to carry out this type of audit.

Auditor Qualifications

Information and guidance to do with process safety audits is provided in our ebook Audits and Assessments.