RMP Audit and Update for Covered Batch Chemical Process in the U.S.

This confidential client uses a highly hazardous chemical in a batch process that is covered under the United States Environmental Protection Agency (USEPA) Risk Management Program (RMP). EHS Support was retained to audit the existing RMP on file with the USEPA and review the written program for the batch process.

Within the past 3 years a personnel change occurred, leading to the departure of the individual responsible for the RMP. Another individual with the company took over the responsibilities of the RMP but had not received adequate training on the requirements of the program. The RMP had not been updated within the past 3 years, nor had personnel changes identifying the new roles and responsibilities associated with the process program been submitted to the USEPA. This personnel change should have been captured by the program’s Management of Change (MOC) program.

EHS Support PSM/RMP experts identified key deadlines established by the client’s own RMP for Compliance Auditing (CA) and Process Hazard Analysis (PHA) revalidation and the deadline for filing an update to the RMP. EHS Support found a CA schedule that was to be completed two years prior to this audit; however, it was never completed, and the company was two years past-due for the required CA of the facility.

The PHA for the covered process was due for 5-year revalidation less than 6 months from the date of the audit. Although the previous individual responsible for the RMP updated the filing of the RMP with the USEPA prior to leaving the company, the filing status was considered a “correction” submission. The actual 5-year anniversary for mandatory resubmission was within 8 months from the date of the audit. Additionally, increased development around the facility over the past 4 years has nearly doubled the population exposure of the facility’s Worst-Case Release Scenario. Information regarding necessary public resources was missing from the company’s Emergency Response Plan, including identification of a school and hospital that were newly considered as public receptors within the distance to endpoint exposure radius.

EHS Support was able to assist with the development and completion of a CA that was carried out as a joint effort between EHS Support and the client as a learning opportunity for the new process supervisor. EHS Support was also able to conduct a PHA revalidation with facility personnel to update the new hazards identified by the initial audit and address findings in the CA. Finally, EHS Support advised the client on how to navigate the USEPA’s website and access the RMP*eSubmit process through the USEPA’s Central Data Exchange to successfully resubmit their current RMP with updated information concerning their Worst-Case Release Scenario.

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