This is our second post in a 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 that we have just completed for OSHA’s Process Safety Management (PSM) standard. The update process is described in the post The EPA RMP Updates. As time permits, we will review and analyze each of their proposed changes. We will also compare them with the comparable OSHA update, where one exists.
Prevention Program (Subparts C and D)
(1) Adding amplifying regulatory text to emphasize that natural hazards (including those that result from climate change) and loss of power are among the hazards that must be addressed in Program 2 hazard reviews and Program 3 process hazard analyses.
There is no corresponding OSHA PSM update.
The EPA states that it is requesting comments on the following.
The Agency’s proposed approach.
The proposed provision to require air pollution control or monitoring equipment associated with prevention and detection of accidental releases from RMP-regulated processes to have standby or backup power and any potential safety issues associated with it.
Loss of power should be considered in all process hazards analyses (PHAs). That should be taken for granted.
Regarding the need for pollution equipment, the text of the proposed change is difficult to interpret. However, experience shows that a sudden loss of power to a process facility can indeed lead to air pollution and flaring. Whether it is feasible to have standby power for the whole facility is questionable. However, it is normal to provide an Uninterruptable Power Supply (UPS) for instrumentation.