One of the weakest elements in OSHA’s PSM and EPA’s RMP standards is the Incident Investigation element. Anyone who has performed a PHA or Audit can tell you that the difference of opinions range from aggressive to the criminally insane! Personally I have heard some of the lamest excuses for not investigating Loss of Primary Containment events, but it gets downright nasty when we ask about “process near misses” being investigated. Since 2016, I now direct those who want to push back about the types of incidents that SHOULD BE investigated to New Jersey’s Toxic Catastrophe Prevention Act (TCPA) Program. In 2016 NJ’s Department of Environmental Protection issued a guidance document explaining, in their opinion, the types of incidents that should be investigated and I for one think they nailed it! The guidance document, Guidance Document on Identifying Process Safety Incidents, is intended to assist TCPA facilities in understanding what incidents must be investigated and how to improve their management systems to identify those incidents when they occur.