EPA and OSHA are getting serious in their RMP enforcement efforts, especially with NH3 refrigeration and refinery piping inspections!

Those that follow my PSM & RMP Citations / Analysis postings most likely have noticed a significant change in the level and depth that EPA and OSHA are conducting their RMP and PSM inspections.  They have cited many more RAGAGEP issues and now dig deep into PHA’s and SOP’s than they ever had before.  This all came about from the National Compliance Initiative: Reducing Accidental Releases at Industrial and Chemical Facilities…

In FY 2020, the EPA continued efforts that were initiated in the prior cycle. The following are illustrative of the agency’s efforts to reduce risks of accidental release at industrial and chemical facilities.

1. Delivered inspector training to EPA, states, local authorities, and OSHA staff – These new inspectors will enhance EPA’s ability to monitor compliance and pursue necessary enforcement actions to address violations.
2. Delivered the three-day Process Hazard Analysis (PHA) training -This specialized course for inspectors from EPA, OSHA, state, and local partners explains the PHA requirements under the Risk Management Program regulations, familiarizes participants with general hazard analysis theory, explains what is necessary to perform a complete PHA, and identify common deficiencies and issues associated with PHA execution. The hazard analysis requirements of both the Risk Management Program regulations and the General Duty Clause are fundamental to identifying the potential causes of chemical accidents and to designing processes so that they are safer and less likely to experience a chemical release.
3. Delivered Ammonia Refrigeration Systems, Technology, and Safety Training – This three-day course is designed for staff from EPA, OSHA, and state and local partners, and is specific to the operation of ammonia refrigeration systems. Ammonia refrigeration is a commonly used process throughout the United States and makes up approximately 40 percent of the facilities regulated under the Risk Management Program.
4. Finalized guidance for inspecting piping at petroleum refineries – A large number of chemical releases at petroleum refineries occur from piping systems. This guidance allows inspectors to focus their activities on ensuring that refineries are monitoring and maintaining their piping sufficiently to reduce the likelihood of accidental releases.