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EPA RMP Inspections – Is Your Facility Next?

June 26th, 2023 by David Webster

HRP has identified a recent number of EPA Risk Management Plan (RMP) compliance inspections at several client’s sites that are subject to Section 112(r) of the Clean Air Act, 42 U.S.C. § 7412(r) and the RMP Program regulations at 40 C.F.R. Part 68.

Based on observations, the subject of these inspections has been limited to registered and actively listed RMP facilities throughout Regions 1 and 2 of the EPA. With the subject matter being reviewed being consistent among sites and including other relevant compliance obligations beyond RMP requirements. The compliance inspections have included:

• EPA RMP requirements;
• OSHA PSM requirements;
• Tier II reporting requirements;
• NFPA and other fire code requirements; and
• OSHA emergency equipment and other relevant OSHA programs that may potentially impact regulated processes.

The inspections have typically lasted a portion of the day to two days. The inspections have typically occurred via a written notification from the EPA requesting documentation to be made available and a site visit to be scheduled. Typically involving a kickoff meeting upon the day of the site visit to review the covered process, safety requirements, and compliance obligations. From there, a walkthrough review is conducted where observations may be noted at that time. A request for documentation is then completed to either be reviewed onsite or reviewed off site at a later time. Upon final documentation review a closeout meeting is scheduled and potential notice of violations may be issued.

Typically, the following compliance obligations have been included in site and documentation reviews:

• RMP submittal documentation;
• RMP certification statements;
• Hazard assessments;
• Five-year accident history;
• Covered process overview;
• Process Safety Information (PSI) and Safety Data Sheets (SDSs);
• List of chemicals at the facility;
• Mechanical integrity program;
• Process Instrument Diagrams (P&IDs);
• Recognized and generally accepted good engineering practices (RAGAGEP);
• Process Hazard Analysis (PHAs) and action items ;
• Operating procedures;
• Training records;
• Preventative maintenance programs and inspection records;
• Management of Change (MOC);
• Pre-Safety Startup Review (PSSR);
• Compliance audits;
• Incident investigations and actions;
• Employee participation;
• Contractor safety programs;
• Hot work programs;
• Lockout Tagout program and procedures;
• Emergency coordination and response plan;
• Tier II submission to SERC, LEPC, and local fire department; and
• Other key safety measures such as alarm systems, detection systems, fire suppression, emergency eyewash and showers, emergency shut offs, pressure relief valves, and other safety systems.

Reach out today, HRP can assist you in preparing for inspections by determining if your facility may be subject to inspection and/or assisting your facility with implementing an RMP program or in preparing for a RMP inspection.

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David Webster, CSP, EH&S Project Manager at HRP Associates, Inc.