If you are covered under OSHA’s PSM regulation you know that you are covered under the EPA’s RMP regulation as well. I understand why most people focus on the PSM regulations – they are used to dealing with OSHA regulations that cover everything from PPE to Lockout/Tagout. Furthermore, if you follow the PSM regulations to the letter, you are essentially covering every single element of the RMP requirements but one.
What amazes me is the general lack of interest, or at least the minor importance that is usually placed by most safety professionals on the Risk Management Plan that is unique to the EPA regulations.
Here are the requested budgets for OSHA and the EPA for fiscal year 2009:
OSHA $501.7 million
EPA $7.14 billion
Now that you see the EPA has nearly 14 and a half times the budget, ask yourself a question: Which one of these agencies is more likely to have the resources to make my life miserable?
Please, take some time to review your EPA required Risk Management Plan.
Here are some things to think about:
Is your RMP management system up to date and are those managers keeping up with their responsibilities under the plan? Has this been audited and documented?
Has every incident that could have resulted in a catastrophic release been investigated and documented?
Have you updated your five year accident history?
Has anything happened that would alter the consequences or likely frequency of your catastrophic release scenarios?
Is your currently filed RMP up to date?
