In recent years, the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) inspections have identified several facilities where a robust system for continuous improvement still needs to be implemented. In some cases, regulated entities have had to make significant changes to their risk management practices and programs due to these inspections.
The RMP is a requirement of the EPA as part of the Clean Air Act Amendments. It requires facilities that use highly hazardous chemicals to develop a Risk Management Plan that: identifies potential accidents, the steps the facility takes to prevent accidents, and the necessary actions should an accident occur.
The EPA conducts RMP inspections to ensure that regulated entities comply with the program requirements and identify areas where improvements can be made. These inspections can be performed at any time and usually involve a review of the entity’s risk management plan and site visits to observe the entity’s risk management and prevention program practices.
The EPA has published several resources to help regulated entities understand the RMP inspection process and what to expect of them. These resources include an RMP Inspection Manual, which guides preparing for and conducting an RMP inspection, and an RMP Inspection Checklist, which can be used to self-assess compliance with the program requirements.
The EPA aims to ensure that regulated entities have a robust system to improve their risk management practices continuously. By conducting RMP inspections, the EPA can identify areas where improvements are needed and guide how to make those improvements.
ETA, Inc. was part of a team to do a pre-inspection review of a client site to identify any ‘holes in the cheese’ that may exist in implementing Risk Management Program objectives/requirements. We applaud our client’s proactive action in identifying and resolving potential concerns before an inspection. Not that this is a new concept since most regulated entities typically have a robust “check and adjust” process for continuous improvement. However, this is an overlooked step in today’s ever-tightening budgets.
The EPA inspection identified only a few minor areas that needed more focus. Before the inspection, all these areas were identified by the ETA pre-review team.
Engineering & Technical Associates, Inc. (ETA) is an engineering consulting and recruiting company that provides consulting and personnel recruiting (both contract and permanent) services to the refining, chemical, and petrochemical industries.