This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are:
1) EPA uses Google and Bing Satellite images in their screening process for who gets inspected
2) A LATE resubmission is #1 on their list to inspect
3) If your process has a Hazard Index >25 you get extra scrutiny
4) EPA will request to see documents “referenced” such as copies of the actual RAGAGEPs that are listed in the process safety documentation
5) EPA will contact the LEPC (RMP toxics)/Fire department (RMP flammables) related to ER planning
See more below…
When Will EPA Discuss Whether to Inspect?
No RMP submitted and…
-
- There are indications that you have Risk Management chemicals greater than threshold
- Tier II reports
- Toxic Release Inventory reports
- Release/ accident reports
- Media, CERCLA/EPCRA, other agencies
- Sector information
- Deregistered facilities appear active (Bing or GoogleEarth) And you thought only the NSA was using the internet to watch what you are doing!!!
- There are indications that you have Risk Management chemicals greater than threshold
RMP Submitted and…
-
- Re-submission is late
- A tip / complaint / referral is received
- RMProgram reportable accident at facility
- Reported on RMP
- Likely should have been reported
- Sector non-compliance
- High risk (FY 2013 = 25% of inspections)
- Previous Risk Management reportable accident
- Population in worst case scenario
- Hazard Index >25
- Most ethanol facilities are “High Risk” due to a lot of flammables on-site (Hazard index of 40-80)
Save Yourself Time – Prepare for the Inspection
- Average ethanol inspection in 2012 was 12 hours over 2 days
- Accident investigations will take longer
- The inspection will go faster if you
- Do some preparation
- Have documentation readily available
- Respond to questions
- Cooperate with the inspection Inspection
Document Review
- Format – Electronic Preferred
- Will scan paper documents
- Can save electronic documents directly to flash drives
- Paper copies were taken if document
- Won’t fit through scanner
- Contains confidential business information (CBI)
- Recommend making a copy/document specific documents inspector takes for future reference.
Inspection – Typical Documents Reviewed
- RMP – submittal responses/dates
- Request to see documents referenced
- Recommend when to submit RMP create file supporting submittal dates & responses
- EPCRA Tier 2 report if not done prior to on-site
- OSHA 300 log (if required) – Looking for chemical accidents
- OCA documentation
- Emergency response documents
Bulk of time spent on prevention program elements
- Safety Information
- Hazard Review/PHA (report & tracking)
- Maintenance (tests/inspections/work orders)
- Compliance audits (report & tracking)
- Incident investigations (report & tracking)
- SOPs (especially emergency related)
- Training
Inspection – Walk thru Usual part for employee representative participation
- Compare physical plant to current industry standards/codes/practices & RMP documents
- Take photos of the condition of the equipment
- Ask random employees questions
- Typically includes control room and maintenance personnel
Post Inspection – Facility Response
- Region 7 allows facilities 10 days to add information as part of the preliminary findings
Post Inspection – Inspectors
- Contact local LEPC (RMP toxics)/Fire department (RMP flammables) related to ER planning
Here is the entire EPA presentation: rmp inspections.pdf