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PT Notes

EPA RMP Rule Amendments - Compliance Audits

PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.

This PT Note describes an amendment to EPA's Risk Management Program (RMP) regulation relating to compliance audit requirements that are part of the rule’s prevention program.

The existing RMP rule requires that facilities with Program 2 and/or Program 3 processes conduct self compliance audits every three years. An amendment to the rule clarifies the applicability of compliance audits. Another amendment introduces requirements for third-party audits which will be described in a further PT Note.

EPA has added language to the RMP rule to clarify that all compliance audits, both self and third-party, shall address compliance with the required provisions of the rule “‘for each covered process’”.

A number of companies historically have performed audits only for a representative sample of processes for a facility so they will view this amendment as a new requirement. However, EPA asserts that it has consistently maintained that the self-compliance audit requirement of the RMP rule applies to each covered process and references statements to that effect in EPA’s General Risk Management Guidance. Thus, companies must conduct compliance audits for all covered processes at a facility to comply with the RMP rule.

Regulated sources have significant discretion in determining covered process boundaries. Some petroleum refineries and large chemical manufacturing facilities containing numerous unit process operations have chosen to consider their entire plant as a single covered process while other similar plants have divided their stationary source into multiple different covered processes. Consequently, the impact of this clarification will depend on how the boundaries of the processes at a facility have been defined as well as how the RMP rule has been applied for each process.

The final rule may be found at:

40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Final Rule

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