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)
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)).
According to the definition in §68.3, administrative controls are written procedural mechanisms used for hazard control. These written procedures must be used to limit the quantity of a substance that can be stored or processed in a vessel or pipe at any one time, or alternatively, occasionally allow a vessel or pipe to store larger than usual quantities.
Although mechanical controls such as alarms may also serve to limit the quantity, EPA does not consider them to be administrative controls and therefore the owner or operator should not include them in the quantity determination for the worst-case scenario.
Additional information on offsite consequence analyses can be found in Chapter 4 of the General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR Part 68) (EPA550-B-04-001).