The five most common violations of Risk Management Program in EPA Region 10 (WA, OR, ID, AK), regardless of chemical or industry, are:
- Process Hazard Analysis § 68.67 (e): The owner or operator shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.
- Management § 68.15 (a): The owner or operator of a stationary source with processes subject to Program 2 or Program 3 shall develop a management system to oversee the implementation of the risk management program elements.
- Documentation § 68.39 :The owner or operator shall maintain the following records on the offsite consequence analyses for the worst-case scenarios, alternative release scenarios, estimated quantity release rate, duration of release, estimated population and environmental receptors potentially affected.
- Updates § 68.190 (a): The owner or operator shall review and update the RMP as specified in paragraph (b) of this section and submit it to the method and format to the central point specified by EPA as of the date of submission.
- Operating procedures § 68.69 (a): The owner or operator shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements, in paragraphs (a)(1) to (a)(4).
Source: EPA Region 10 – Chemical Emergency Prevention & Planning Newsletter