One of the recent amendments of EPA’s RMP rule impacted our Incident Investigation procedures/practices and most likely any report forms we had been using for years and years. The RMP and PSM Incident Investigation elements used to be very similar and thus most of us used the same procedure/practices and forms when trying to comply with the two (2) elements. But now, since EPA had to implement the RMP amendments, 40 CFR Part 68.81 Incident Investigation for Program 3 processes, we have some very different requirements from OSHA’s PSM Incident Investigation requirements. For example, we are now required to generate a written report at the conclusion of the investigation within 12 months of the incident, unless the implementing agency approves, in writing, an extension of time. PLEASE NOTE, the investigation still has to be started within 48-hours following the incident, we just now have a timeline as to when the written report must be completed by.
And this incident report has five (5) additional documentation requirements above what our old incident reports had to contain and these may require some facilities to implement some new practices. Here is a look at these new requirements for RMP Incident Investigations: