Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls?
EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a written procedure to control inventory involved in the Worst-Case Release scenario. Technically speaking, I can see how this FAQ was written, as there is a difference between administrative controls and engineering controls – but to state that an alarm/interlock would not be accepted and that the administrative control is required over-and-above the engineering control is “compliance non-sense”. I have always required BOTH (SOP and Hi-Level controls); not even sure how we can run a process without the administrative controls. But unless EPA is doing inspections on a different planet than I work on – administrative controls were written to be broken! (My words not EPA’s)