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PT Notes

EPA RFI - RAGAGEP, Mechanical Integrity of Safety-Critical Equipment, and Management of Organizational Changes

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

On July 24, 2014, the U.S. Environmental Protection Agency (EPA) announced a Request for Information (RFI) seeking comments on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations. Multiple issues were addressed in the RFI. This PTNote addresses three of the issues.

One of the issues addresses defining and requiring the evaluation of updates to applicable recognized and generally accepted good engineering practices (RAGAGEP). The Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard and EPA's RMP rule contain essentially identical references to RAGAGEP.

Questions posed by EPA on this issue include:

  1. What does your facility use as a definition for RAGAGEP? Would adding a definition for RAGAGEP to the RMP rule improve understanding of RMP requirements and prevent accidental releases? If so, what specific definition for RAGAGEP should EPA add to the RMP rule? What would be the economic impacts of adding such a definition?
     
  2. From what sources (e.g., codes, standards, published technical reports, guidelines, etc.) does your facility select applicable RAGAGEP for operations covered under the PSM standard?
     
  3. Does your facility evaluate updates to its selected RAGAGEP? If so, how does your facility monitor any updates, and how often do you evaluate them?
     
  4. Can you provide any data or information on accidents, near misses, or other safety-related incidents involving failure to evaluate and/or implement updates to applicable RAGAGEP for RMP-covered processes? Would requiring employers to evaluate and/or implement updates to applicable RAGAGEP prevent such accidental releases?
     
  5. Should owners or operators covered by the applicable provisions of the RMP regulation be required to evaluate updates to applicable RAGAGEP? Should owners and operators be required to comply with new RAGAGEP requirements that occur after the owner or operator's initial compliance with the applicable provision of the RMP rule? How would such updates or new requirements be identified? What would be an appropriate time period in which to conduct this evaluation and/or to comply with updated RAGAGEP? What would be the economic impacts of this change?
     
  6. Would a requirement to evaluate updates to applicable RAGAGEP be more appropriate in another paragraph of the RMP rule? For example, should such a requirement become part of the process hazard analysis (PHA) revalidation requirements at § 68.67(f), or the management of change requirements at § 68.75? How would EPA incorporate such a requirement for Program 2 processes?

Another issue addresses extending mechanical integrity (MI) requirements to cover any safety-critical equipment. EPA is interested in receiving information on whether the scope of the MI provisions of the RMP rule should be expanded to cover the MI of any safety-critical equipment, and whether additional MI requirements should be added to the rule's provisions.

In its RFI, OSHA notes that the MI provisions of the PSM standard apply to six specific categories of equipment, including pressure vessels and storage tanks, piping systems (including piping components such as valves), relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. These categories of equipment encompass most safety-critical equipment within regulated processes. However, during some compliance inspections, EPA has observed that facilities have failed to apply MI program measures to certain additional types of equipment and systems that could reasonably be judged to be critical to process safety. Examples of such equipment include computer software systems that interact with process components, electrical power systems, and other utility systems that interact with pumps, valves, or control systems.

EPA notes that the RMP Program 2 maintenance requirements, which were intended as a streamlined version of the MI requirements for Program 3 processes, apply to all process equipment, rather than being restricted to specific categories of equipment. Potentially, this causes the unintended result of requiring certain aspects of a process subject to Program 2 to meet more rigorous maintenance requirements than the same equipment located in a Program 3 process. EPA is interested in receiving feedback on whether expanding the scope of the Program 3 MI requirements or reducing the scope of the Program 2 maintenance requirements would address this potential discrepancy appropriately.

In addition to expanding the scope of the rule's existing MI provisions to cover any safety-critical equipment, EPA is also interested in whether additional requirements should be added, or whether any existing requirements need to be clarified. For example, emergency shutdown systems are one type of process equipment covered under the rule's MI provisions. However, the regulation does not explicitly require that all covered sources install emergency shutdown systems.

Questions posed by EPA on this issue include:

  1. Should EPA amend the MI provisions of the RMP rule to cover explicitly all safety-critical process equipment? If so, what type(s) of equipment? Did you identify safety-critical equipment not explicitly covered under § 68.73? If so, how did your facility determine that the equipment was safety-critical, and does your facility treat the equipment as if it were RMP-covered for safety or other reasons? Did you identify the equipment as safety-critical through an RMP PHA?
     
  2. Can you provide any data or information on accidental releases, near misses, or other safety-related incidents related to the MI of safety-critical equipment not explicitly covered under § 68.73.
     
  3. Would expanding the scope of § 68.73 to cover explicitly the integrity of all equipment critical to process safety make it more likely to prevent accidental releases?
     
  4. Should EPA add additional requirements to the MI provisions, or clarify any existing provisions? For example, should EPA require that certain types of covered facilities install emergency shutdown systems, such as redundant power supplies, emergency flares, vents, or scrubbers, etc., in order to prevent accidental releases resulting from uncontrolled emergency shutdowns?
     
  5. Are there any other provisions of § 68.73 that should be enhanced or clarified? Does labeling § 68.73 as "Mechanical Integrity" cause owners and operators to disregard or neglect the maintenance, functionality, or integrity of process components that would not typically be considered "mechanical" components, such as electrical and computer systems?
     
  6. What would be the economic impacts of revising the MI provisions as discussed above? Are there any special circumstances involving small entities that EPA should consider with respect to revising the MI provisions of the RMP?

An additional issue addresses requiring owners and operators to manage organizational changes. OSHA 's RFI notes that the PSM standard does not explicitly require employers to follow management of change procedures for organizational changes, such as changes in management structure, budget cuts, or personnel changes. However, OSHA's RFI highlights a policy interpretation that OSHA's view is that the PSM standard does cover organizational changes if the changes have the potential to affect process safety. The RMP rule contains management of change requirements for Program 3 processes (see § 68.75) that are virtually identical to the PSM standard. Therefore, EPA is interested in receiving public comment on whether the RMP rule's management of change requirements should be expanded to include management of organizational changes.

Questions posed by EPA on this issue include:

  1. What do you consider to be an organizational change within the context of process safety management practices? For example, would you consider the following, or similar, changes to be organizational changes: reducing the number of operators in a shift; changing from 5-day to 7-day operations; changing from 8-hour to 12-hour operator shifts; replacing a unit manager; reducing the facility operations or maintenance budget; relocating a technical group to a remote corporate location; changing a supervisory or compensation structure; or hiring contractors to do work formerly performed by employees of the regulated facility? Are there other examples of organizational changes that may be relevant to safety management practices?
     
  2. If your facility has established and implemented written procedures for management of organizational changes, please describe any economic impacts associated with the procedures. Please note any implementation challenges that may be associated with requiring that such procedures be developed and followed.
     
  3. Would clarifying § 68.75 with an explicit requirement that employers manage organizational changes prevent accidental releases? What would be the economic impact of such a clarification? Are there any special circumstances involving small entities that EPA should consider with respect to this option?
     
  4. Can you describe any organizational changes made in your facility that have had the potential to affect process operations? Were management of change procedures followed before making the changes?
     
  5. What do you consider to be the best safety practices concerning management of organizational change?
     
  6. Can you provide any data or information on accidents, near misses, or other safety-related incidents involving the failure to manage organizational change? Would following management of change procedures under § 68.75 have prevented these incidents?

Further details on these issues are provided in EPA's RFI which can be accessed by clicking here.

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