As part of GCAP’s PSM course, we pull the publically available RMP from RTKnet.org for each facility in the class. We’ve seem some strange things in the Executive Summary and wanted to share some guidance on what exactly should and should not be there.
First, let’s look at the most common mistakes:
1) Misunderstandings of Executive Summary: The Executive Summary is meant to be a quick synopsis of the RMP filing, not a brief summary of the executives at the facility. Seriously, a facility had actually put mini-resumes of the executives at the facility in their executive summary.
2) Long, rambling consultant boilerplate: The Executive Summary is supposed to be brief and include only the required information. Reading some of the Executive Summary’s, you would think that the consultants were paid by the word.
3) The OCA or Offsite Consequence Analysis: While this information was originally required, the law was changed in 2004 to remove this requirement due to National Security concerns. As explained by the EPA:
“A summary of the off-site consequence analysis (OCA) for the worst-case and alternative release scenarios(s) is no longer required to be included in the Executive Summary. While the RMP rule originally required that the Executive Summary briefly describe the OCA for worst-case and alternative release scenario(s), EPA amended the RMP rule in 2004 to remove this requirement because of security concerns. Your Executive Summary should not describe nor include information concerning your worst case or alternative release scenarios.” —-EPA 555-B-09-001
4) Misunderstandings of “Planned changes to improve safety”: Occasionally, you will see someone like EVERY PHA, II, CA and MI recommendation in the system and the status of that recommendation. The EPA says they expect you to list the following:
“..any upcoming events such as training, installation of new mitigation or control equipment or technology, organizational changes, etc., that will improve safety at your facility. —EPA 555-B-09-001“
Usually you can simply provide a statement such as “Through our ongoing implementation of the PSM/RMP program, ABC Company looks continuously for possible ammonia refrigeration system changes to improve safety in our facility.
What should the Executive Summary include? First, let’s look at the purpose of the executive summary:
“The Executive Summary must include a brief description of your facility’s risk management program. You determine the length; it may be as short as two or three pages or, if you have many processes, it may need to be longer. You should view the Executive Summary as an opportunity to communicate in your own words the nature of the risks posed by your facility to your community and to explain what you have done to minimize those risks. The summary can be an excellent vehicle to display the effort and resources your facility has put into its accident prevention program. —EPA 555-B-09-001“
Here is the information actually required in the Executive Summary:
- The accidental release prevention and emergency response policies at your facility. Describe your facility’s overall approach to chemical safety. You may want to include any corporate policies (if applicable) and an overview of senior management commitment to safety and implementation of safe procedures.
- Your facility and the regulated substances handled. Provide a description of your facility so that the public has a clear picture of the facility, its processes, and products. Describe the primary activities at the facility (e.g., manufacturer of polyethylene, pulp mill, etc.) and the regulated substances used.
- The general accidental release prevention program and chemical-specific prevention steps. You may wish to mention the rules and regulations with which your facility complies, such as the OSHA PSM rule. You should also highlight practices that you believe are important to your prevention program. The steps you list may be either technological (e.g., backup systems) or procedural/managerial (e.g., improved maintenance or training).
- The five-year accident history. This should be a written summary; for example, “We have had five accidental releases of chlorine in the past five years; the largest release was 1,500 pounds. No one offsite was injured, but several houses were evacuated as a precautionary measure during the October 2005 and May 2006 releases.”
- The emergency response program. Briefly describe the elements of your response program. These may include coordination with local emergency responders, training received by personnel, drills conducted by your facility, public notification and alert systems, as appropriate
- Planned changes to improve safety. List any upcoming events, such as training, installation of new mitigation or control equipment or technology, organizational changes, etc., that will improve safety at your facility.