EPA RMP Regulations

The EPA RMP regulation and the European Community s Seveso II directive both exempt covered processes from some regulatory provisions, if the facility documents the absence of catastrophic damage from process accidents under reasonable worst case conditions. The State of New Jersey is also considering similar action in its proposed revisions of the Toxic Catastrophe Prevention Act (TCPA) regulations. 

The OSHA PSM Standard and the EPA RMP regulation do not explicitly require the use of multiple sources when compiling process safety information. 

Neither the OSHA PSM Standard nor the EPA RMP regulation explicitly requires specific hazards, such as reactive hazards, to be examined when performing a process hazard analysis. 

The definition of public impact is based on the criteria for reporting offsite incidents in the EPA RMP regulation (40 CFR 68.42a). Public includes anyone except employees or contractors at the facility. 

CSB incident data were analyzed with respect to coverage under the EPA RMP regulation ... 

There are significant differences in the laws authorizing the OSHA PSM Standard and the EPA RMP regulation. Because EPA specifically lists substances covered under RMP and does not establish classes of substances, this report separately discusses alternatives for OSHA (Section 8.1) and EPA (Section 8.2). (Section 8.3 briefly discusses regulatory relief absent catastrophic consequences, and Section 8.4 suggests improvements within the requirements of the existing PSM Standard and RMP regulation to enhance hazard identification and hazard evaluation.)... 

To most effectively improve reactive hazard management, coverage under the OSHA PSM Standard and the EPA RMP regulation should be more compatible. EPA should seek the authority needed to allow it to address reactive hazard coverage in a manner compatible with any revised OSHA approach. 

The PSI element of both the OSHA PSM Standard and the EPA RMP regulation can be improved by requiring the inclusion of all existing information on chemical reactivity. Examples of such information are chemical reactivity test data, such as DSC, thermogravimetric analysis (TGA), or accelerating rate calorimetry and relevant incident reports from the plant, the corporation, industry, and government. OSHA and EPA should require the facility to consult such resources as Bretherick s Handbook of Reactive Chemical Hazards,Sax s Dangerous Properties of Industrial Materials, and computerized tools (e g., CHETAH, The Chemical Reactivity Work Sheet). 

In both the OSHA PSM Standard and the EPA RMP regulation, the PHA element does not currently specify the factors that must be considered to effectively manage reactive hazards. Present requirements should be augmented to explicitly require an evaluation of such factors as rate and quantity of heat generated maximum operating temperature to avoid decomposition thermostability of reactants, reaction mixtures, byproduct waste streams, and products effect of charging rates, catalyst addition, and possible contaminants and understanding the consequences of runaway reactions or toxic gas evolution. 

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