Environmental Compliance Management Services
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1 Environmental Compliance Management Services
2 Is It That Time Again?
3 Who's ECM Services? Specialize in Regulatory Compliance for Industrial Operations with over 20 years of hands-on experience Regulatory Experts Industrial Chemistry Manufacturing and Process Engineering Risk-Based Approach to Compliance Management: Manage The Risk-Don t Chase the Regulation EMS/ISO Lead Auditor Certified Developed 100 s of successful and effective multimedia industrial compliance programs, including nearly 100 RMPs, in the toughest regulatory environments for some of the most highhazard/complex industrial operations
4 Regulatory Background 40 CFR 68: Accidental Release Prevention Program Section 112(r) of the 1990 Clean Air Act Citizen Right to Sue Provisions Regulated Substances (RS) Above Threshold Quantities (TQs) 40 CFR 355 Ammonia, Anhydrous: TQ= 10,000# Ammonia, 20% : TQ= 20,000# Chlorine: TQ= 2,500# Propane: 10,000 # State/Local TQs (California s CalARP) Ammonia, 1%: TQ= 1,000# Chlorine: TQ= 100#
5 Program Levels Program 1 No Offsite impacts No accidents w/in last 5 years Program 2 Not either Program 1 or Program 3 Program 3 Subject to OSHA Process Safety Management Regulations Certain specified industrial classifications
6 5-Year Review & Update At least once every five years from the date of initial submission: Revise and Update the RMP and re-submit Review and update Offsite Consequence Analysis (OCA) Update and revalidate PHA, Prevention & Management Programs Steps to Compliance: Goal: Defendable & Technically Justified Review last 5-year history of regulated process Verify/update that previous PHAs, Hazard Assessment, hazard prevention and management programs represent current process conditions and controls are appropriate and adequate for current conditions Resubmit RMP documentation/registration to EPA/Administrating Agency
7 Risk Management Program "Continuous Improvement" Review Revise Hazard Assessment Monitor Measure Continuous Process Identity Risk and Controls Inspection & Record Keeping Continuous Process Prevention Program Implement Management Program
8 RMP Update & Revalidation Do not have to start from scratch Quality of Previous PHAs Changes to Processes In Last 5 Years Adequacy of Prevention Program Elements Effectiveness of Management Program Elements
9 Hazard Assessment Review Process History Changes to Process Equipment (MOC/PSSR) PSI/P&IDs Maintenance Records Incident Investigations (Releases and Near-Miss) Operating, Safety Procedures Company Policies Personnel/Sitting Changes Employee turnover/knowledge Base Land Use/Development Regulatory Changes DHS Chemical Facility Anti-terrorism Standards (CFATs)
10 Hazard Assessment Apply history and verify/update that: PHAs adequately represents current process conditions; and Hazard Controls (i.e., prevention and management programs) are effective and appropriate for current process conditions Technically justified Demonstrated
11 PHAs Quality of Previous PHAs Complete/Through? All fail modes identified & evaluated: PHA Method Review Critical Fail Points: Process Flow Diagram Nodes Chemical or physical change in regulated substance Requires personnel to make process decision and take action Consequences of Deviation From Design Conditions 1 st :Possibility 2 nd : Probability, considering existing controls External Events PHA Results Drive Prevention and Management Programs
12 Prevention and Mangement Program Requirments Nearly all RMP violations are a result of failure to implement adequate prevention and management programs Where compliance is measured and where the real work begins Prevention Program: Systems, procedures and programs to prevent and/or mitigate a release of the regulated substance PHA Results Technically Justified Document, measure Prevention Program effectiveness and adequacy ECM Services RMP Compliance Management Tool
13 Overview RMP Program Administration Prevention Program PSM DEMONSTRATION OF COMPLIANCE Recording Keeping and Document Control RMP ISM Database Management Element Program Element Review Equipment Maintenance (Mechanical Integrity) Administration Contractor Management MOC/PSSR Training and Qualification RAPs
14 RMP Compliance Management Tool (RMP CMT) Structure RMP CMT Elements Program Management Procedures: 1. Section A: Policy 2. Section B: Employee Participation 3. Section C: PSI 4. Section D: PHA 5. Section E: Operating Procedures a. OPs b. MPs 6. Section F: Training 7. Section G: Contractors 8. Section H: Mechanical Integrity a. Equipment/Process Maintenance & Inspection Program 9. Section I: Hot Work (SWP) 10. Section J: MOC/PSSR 11. Section K: Incident Investigation 12. Section L: Emergency Response Planning/EPs 13. Section M: Compliance Audits 14. Section N: Document Control 15. Section P: Recommendation Action Plan (RAP) RMP Information Management System (IMS): 1. Equipment Classification Data (Data Elements Forms/PSI) 2. Contractor Information 3. PM Requirements 4. PM Schedule 5. PM Log 6. MRR Report 7. Training Requirements & Schedule a. Employees b. Contractors 8. Document Control Records a. Program Management Procedures b. SOPs (OPs) c. MOPs (MPs) d. SWPs e. EPs f. Training Programs g. Process Flow Diagrams /PI&Ds h. Process Hazard Review (PHAs) i. RMP Review: 5-year 9. RAP Reports 10. MOC/PSSR Reports 11. Compliance Audit Reports 12. Incident Investigation Reports
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16 MAIN MENU UPDATE CODE LISTS PROGRAM ELEMENT REVIEW REPORTS Compliance Schedule OPs & EPs CODE UPDATE OPs & EPs DESCRIPTION UPDATE SAFETY CODE UPDATE EDIT/REVIEW EXISTING RECORD PROGRAM ELEMENT FORM ADD NEW RECORD PROGRAM ELEMENT UPDATE
17 MAIN MENU GENERAL EMPLOYEE ADMINISTRATIVE TASKS Employee Demographic Information ADMINISTRATION REPORTS Compliance Schedule ADD NEW RECORD EDIT/REVIEW EXISTING RECORD PSSR CONTRACTOR MANAGEMENT RAP INCIDENT INVESTIGATION 1. Request For Change 2. PSSR Header 3. PSSR Checklist 1. General Information 2. Performance Evaluation 3. Quality Evaluation 4. Training Records 1. Header Form 2. Preferred RAP 3. Alterative RAP 4. Review & Approval
18 Management Process Flowchart MOC RAP PSSR PHA 5- Yr PHA Review PSI SOPs MOPs 3 Yr Compliance Audit SWPs Incident Investigation Document Control Training ERPs Review and update written procedures, training program materials Log changes in DB Review/update DB elements
19 RMP ValidationTeam Critical to success of the RMP Update and Revalidation Process Resources: Diverse and Intensive Expertise Required RMP Compliance Regulatory Specialist Understands the regulation and how to apply it and the compliance tools to the industrial setting/process Buffer between regulated facility and the regulator/ enforcement agency in determining RMP Compliance Increase in RMP enforcement actions in CA up over 300% since Process Experts: YOU 1: Based on Sacramento County CUPA Enforcement & Inspection Plan
20 RMP Validation Facilitation
21 QUESTIONS? MAUREEN DAGGETT REA, CHMM, CPESC, CPSWQ, CISEC
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