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EPA RFI Published in the Federal Register

Publish Date: 2014-07-31
Category: Industry News

A Request For Information (RFI) from the Environmental Protection Agency (EPA) requesting comment on potential revisions to its Risk Management Program regulations and related programs was published in the Federal Register on 07/31/2014.

EPA is asking for information and data on specific regulatory elements and process safety management approaches, the public and environmental health and safety risks they address, and the costs and burdens they may entail. EPA will use the information received in response to the RFI to inform what action, if any, it may take.

There is a 90-day comment period that ends on 10/29/2014.

Primatech is issuing a series of PT Notes relating to various aspects of EPA's RFI. An archive of PT Notes is available by clicking here.

The RFI can be accessed by clicking here.

Copyright © 2014, Primatech Inc. All rights reserved.

EPA Seeks Comments on Potential Revisions to its Risk Management Program

Publish Date: 2014-07-24
Category: Industry News

On July 24, 2014, the U.S. Environmental Protection Agency (EPA) made available a pre-publication version of a Request for Information (RFI) seeking comments on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations as required under Executive Order (EO) 13650: Improving Chemical Facility Safety and Security. The EPA will use the information received in response to the RFI to inform what action, if any, it may take.

EPA's RFI closely coordinates with potential changes to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) program for accident prevention measures. OSHA issued an RFI on potential changes to its PSM standard on December 9, 2013. OSHA's RFI requested information on 17 potential policy and rulemaking topics relating to modernization of the PSM standard and other related OSHA standards.

Topics are divided into two categories in EPA's RFI: those addressed in parallel to OSHA's RFI, and additional topics not raised by OSHA.

Items in OSHA's RFI relevant to EPA's RMP regulation include:

  • Update the list of regulated substances
  • Additional risk management program elements
  • Define and require evaluation of updates to applicable recognized and generally accepted good engineering practices
  • Extend mechanical integrity requirements to cover any safety critical equipment
  • Require owners and operators to manage organizational changes
  • Require third party compliance audits
  • Effects of OSHA PSM coverage on RMP applicability

Additional items for which EPA is requesting information include:

  • Safer technology and alternatives analysis
  • Emergency drills to test a source's emergency response program or plan
  • Automated detection and monitoring for releases of regulated substances
  • Additional stationary source location requirements
  • Compliance with emergency response program requirements in coordination with local responders
  • Incident investigation and accident history requirements
  • Worst case release scenario quantity requirements for processes involving numerous small vessels stored together
  • Public disclosure of information to promote regulatory compliance and improve community understanding of chemical risks
  • Threshold quantities and off site consequence analysis endpoints for regulated substances based on acute exposure guideline level toxicity values
  • Program 3 NAICS codes based on RMP accident history data
  • The "safety case" regulatory model
  • Streamlining RMP requirements

Once EPA's RFI is published in the Federal Register, there will be a 90 day period for commenters to provide information and data on specific regulatory elements and process safety management approaches, the public and environmental health and safety risks they address, and the costs and burdens they may entail.

Primatech will be issuing a series of PTNotes elaborating on various aspects of EPA's RFI. For more information, click on these links:



Executive Order 13650, Report for the President, Actions to Improve Chemical Facility Safety and Security - A Shared Commitment

Report to the President: Actions to Improve Chemical Facility Safety and Security

Publish Date: 2014-06-12
Category: Industry News

A status report was released on June 6, 2014 by the Working Group set up to respond to the Executive Order (EO) 13650 issued on August 1, 2013 to address the improvement of the safety and security of chemical facilities and reduce the risks of hazardous chemicals to facility workers and operators, communities, and responders.

The report, Actions to Improve Chemical Facility Safety and Security – A Shared Commitment, summarizes the Working Group's progress, focusing on actions to date, findings and lessons learned, challenges, and short and long-term priority actions. It is available at:


CSB Video on Deepwater Horizon Blowout

Publish Date: 2014-06-09
Category: Industry News

On June 5, 2014, the U. S. Chemical Safety Board released a computer animation recreating the Deepwater Horizon blowout that occurred on April 20, 2010. The video depicts how high-pressure oil and gas from the Macondo well in the Gulf of Mexico caused an explosion on the drilling rig that killed 11 workers, seriously injured 17 other workers, triggered the largest oil spill in U.S. history, and destroyed the drilling rig.

The video illustrates how the Deepwater Horizon's blowout preventer failed to seal the well owing to buckling of the drill pipe caused by a mechanism known as effective compression. The video warns that this could make existing blowout preventer designs less effective in emergency situations.

The video can be viewed or downloaded at:


Primatech's Dr. Paul Baybutt authors paper on the use of risk matrices and risk graphs for SIL determination

Publish Date: 2014-06-09
Category: Primatech News

The paper was published in Process Safety Progress, Vol. 33, Issue 2, Pages 179–182, June 2014.


Risk matrices and risk graphs are used to determine safety integrity levels for safety instrumented functions. Their simplicity makes them appealing but various difficulties militate against their use for this purpose. These difficulties include the accommodation of hazardous events, allocation of risk tolerance criteria for calibration, and consideration of overall facility risk. Layers of protection analysis and other more quantitative methods are better able to handle these issues.

Consultation on Draft COMAH Regulations 2015

Publish Date: 2014-05-06
Category: Industry News

The U.K. Health and Safety Executive (HSE) has issued a consultative document seeking views on proposed new regulations, titled "The Control of Major Accident Hazards Regulations 2015", to assist in implementing the Seveso III Directive on the control of major-accident hazards involving dangerous substances.

Changes to the regulations include moving to a new chemical classification system and making site and hazards information available to the public. Other changes relate to safety reports, notifications, emergency plans, definitions of key terms, and the treatment of domino effects.

The consultation began on May 2, 2014 and will end on June 27, 2014.

Further information and the consultative document are available at:


CSB Report on Tesoro Anacortes Refinery Accident

Publish Date: 2014-05-05
Category: Industry News

The U.S. Chemical Safety Board approved a report and recommendations on the Tesoro Refinery Accident Investigation presented at a public meeting in Anacortes, Washington on May 1, 2014. The accident occurred in April, 2010 and involved a heat exchanger explosion and fire that killed seven people.

Among the report recommendations the CSB is calling on the U. S. Environmental Protection Agency to revise rules in its Chemical Accident Prevention Provisions to require the use of inherently safer systems analysis and a "hierarchy of controls" to the greatest extent feasible when facilities are establishing safeguards for identified process hazards with the goal of reducing the risk of major accidents to "as low as reasonably practicable," a concept abbreviated as ALARP.

Also, the CSB recommends that Washington state require refineries to develop comprehensive process hazard analyses (PHAs) which include a rigorous analysis of process hazards and their safeguards, documented rationale of safeguard effectiveness, documented damage mechanism hazard reviews conducted by a diverse team of qualified personnel, and documented use of inherently safer systems analysis and the hierarchy of controls.

The report is available at:


CSB Analysis of Hydrogen Explosion at Silver Eagle Refinery

Publish Date: 2014-04-10
Category: Industry News

A massive explosion and fire occurred on November 4, 2009 at the Silver Eagle Refinery in Woods Cross, Utah. It damaged over 100 homes in a nearby neighborhood and caused four workers to be blown to the ground although they were not seriously injured. The CSB has found that the accident was caused by the rupture of a pipe that had become dangerously thin from corrosion.

Click here for more information.

Comments Available on OSHA PSM RFI

Publish Date: 2014-04-10
Category: Industry News

Comments submitted in response to the Request for Information by the US Occupational Safety and Health Administration (OSHA) on potential revisions to the Process Safety Management (PSM) standard are available at www.regulations.gov, docket number OSHA-2013-0020.

Click here to access the comments.

Primatech's Dr. Paul Baybutt authors paper on the ALARP principle in process safety

Publish Date: 2014-04-10
Category: Primatech News

The paper was published in Process Safety Progress,Vol. 33, Issue 1, Pages: 36-40, March 2014.


The principle that the risks for a facility should be reduced to as low as reasonably practicable (ALARP) increasingly is embraced around the world. This article describes how the principle can be used to establish both individual and group risk tolerance criteria which are needed for risk analysis studies using techniques such as Layers of Protection Analysis (LOPA). The consideration of uncertainties in risk estimates in the ALARP context and the use of the precautionary principle are also described and the use of cost-benefit analysis in applying the ALARP principle is discussed. Other related principles used in risk management are described.