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  • Applicability of prevention program for complex processes

    My process is a series of storage and process vessels, connected by piping, containing several regulated substances, with a few co-located tanks of other substances. Do I have to implement one prevention program to cover all aspects of the process even if different operators, different process chemistry, and different hazards…

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  • Does an owner or operator of a facility with a Program 3 process need to maintain Material Safety Data Sheets (MSDSs) under the risk management program regulations?

    An owner or operator of a facility with a Program 3 process must compile information pertaining to the hazards of the regulated substances in the process, including toxicity information; permissible exposure limits; physical data; reactivity data; corrosivity data; thermal and chemical stability data; and hazardous effects of inadvertent mixing of…

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  • What constitutes a revision of the PHA?

    The rule states that I have to update my RMP whenever I revise a PHA. What constitutes a revised PHA? Every time I go through management of change procedures I make a notation in the PHA file for the process, but would that constitute a revised PHA if the change…

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  • PHA revisions to consider offsite consequences

    If I need to revise a PHA to consider off-site consequences, when do I have to do that? In general, for a PHA originally completed to meet the requirements of OSHA PSM that did not consider offsite consequences, you should revise the PHA to consider offsite consequences when you update…

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  • Hot Work Permit Review Date

    Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What date should the owner or operator enter in…

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  • Complying with process safety information (PSI) resulting from new and updated recognized and generally accepted good engineering practices (RAGAGEP)

    My Program 3 process was built prior to new and updated recognized and generally accepted good engineering practices (RAGAGEP) for my industry. Do I need to implement the new industry practices to comply with process safety information (PSI) requirements under 40 CFR §68.65? EPA expects owners and operators to regularly…

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  • Is EPA's PHA stationary source siting requirement analogous to OSHA's PSM?

    Does EPA interpret the Program 3 process hazard analysis - stationary source siting requirement analogously to OSHA's Process Safety Management standard? Yes. The requirement to consider stationary source siting during the process hazard analysis means that you should consider the location of the covered vessels and evaluate whether their location…

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  • What do I have to do for material and energy balances?

    For new processes, you must document both material and energy inputs and outputs of a process. For example, you would document the quantity of a regulated substance added to the process, the quantity consumed during the process, and the quantity that remains in the output. This requirement will not generally…

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  • Owner / Operator Compliance Audit Timeline

    The regulations in 40 CFR §§68.58 and 68.79 require the owner or operator of facilities to conduct and document compliance audits at least every three years, although an owner or operator is not required to conduct a compliance audit prior to submitting a facility’s first RMP. Must an owner or…

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  • Program Level 2 and 3 compliance audits

    Facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). How does a facility submit its compliance audit to EPA? Facilities are not required to submit three year compliance audits to EPA; however, facilities should maintain records…

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  • Maintenance requirements for leased tanks

    I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do? As part of your contract with the supplier, it would be helpful to gain…

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  • When must an incident investigation be initiated for Program 2 and 3 processes?

    When must a stationary source owner or operator begin conducting incident investigations as required under 40 CFR §68.60 (for Program 2 processes) or 40 CFR §68.81 (for Program 3 processes)? For both Program 2 and Program 3 processes, the incident investigation must be initiated as soon as possible, but not…

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  • Breaking a process into separate units to comply with prevention program requirements

    Do I have to do my hazard review, process hazard analysis, or other prevention activity on the whole process or can I break it into separate units? Once you have determined that you have a covered process, you can divide the covered process any way you want to implement the…

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  • Applicability of compliance audit provisions to emergency response programs

    I have a Program 2 covered process and a Program 3 covered process at my stationary source, and I am required to conduct compliance audits certifying that I have evaluated compliance with my prevention program requirements at least every three years (40 CFR Sections 68.58 and 68.79). Do these provisions…

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  • What does "materials of construction" mean?

    What does “materials of construction” apply to and how do I find this information? You must document the materials of construction for all process equipment in a covered process. For example, you need to know the materials of construction for process vessels, storage vessels, piping, hoses, valves, and flanges. Equipment…

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