PT Notes
EPA RMP Rule 2024 Amendments - STAA Performance
PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.
The amended RMP rule requires that Program 3 Process Hazard Analysis address STAA, which involves the application of the hierarchy of controls for process safeguards.
EPA believes that STAA can be incorporated into RMP PHAs by using PHA techniques such as the Hazard and Operability Study (HAZOP), What-If Method, checklists, a combination of these techniques, or other appropriate equivalent methods. EPA states that these techniques themselves are not requirements, but rather tools available to help the facility owner or operator to identify, evaluate, and control the hazards involved in a process.
Facilities may, if desired, conduct a separate STAA analysis of each entire process, outside of the PHA process, provided it is performed in the same timeframe as the PHA, and the results are documented.
If a facility does not have staff capable of identifying and evaluating alternatives, the facility owner or operator may obtain outside assistance from engineering firms or consultants.
For situations where a STAA involves a novel process that is entirely different from a current process, EPA’s view is that the process design must exist or be developed within the industry, and PSI be compiled, to conduct a PHA for the new process. EPA does not expect facility owners or operators to research and create new processes or conduct research into all possibilities for the use of new chemicals. Instead, the STAA should focus on known and existing substitute processes and chemicals that have been demonstrated to be safe in commercial use.
If a facility is considering an IST chemical substitution or process change from their STAA that involves a significant redesign of their process, such efforts involved with redesign and its evaluation may need to be undertaken as part of a practicability study, which is discussed in a separate PT Note.
The definition of practicability allows for consideration of technological factors, which could include whether a potential safer alternative can be designed and operated to meet the process functions needed. However, not all IST involves substituting a chemical or an entirely new process. Also, there are other types of IST measures (minimization, moderation, or simplification) that can be considered to address various points within the current process where hazards and risks exist.
Furthermore, EPA has accounted for the technical capabilities of facilities in the sectors targeted for STAA when determining reasonable requirements that provide for the prevention of accidents to the greatest extent practicable.
Due to the performance-based approach of the current RMP PHA requirements to identify, evaluate, and control the hazards involved in the process, EPA believes some facilities may have already performed a STAA-type analysis as part of their PHA. If the facility has already performed such an analysis in the past, then the owner or operator should consider these analyses when updating or revalidating their PHAs and determine whether there is new information that should be considered as part of conducting the current STAA.
EPA believes that the STAA should identify potential IST process changes that, if implemented, would result in owners or operators using less hazardous substances, minimizing the amount of regulated substances present in a process, moderating process conditions and reducing process complexity. The STAA also should identify potential passive, active, or procedural safeguards that, when implemented, will result in changes to make processes safer. Such changes help reduce the prevalence of higher risk processes and thereby prevent accidents by (1) eliminating the possibility of an accidental release entirely, by making a process more fault-tolerant, such that a minor process upset or equipment malfunction does not result in a serious accidental release; and/or (2) reducing the severity of releases that do occur.
EPA believes that actions that prevent or reduce the severity of accidents in RMP processes are also likely to prevent or mitigate non-RMP accidents at the same facilities because the same or similar actions can be taken for processes and equipment not subject to the regulation, often at minimal additional cost.
For IST/ISD practicability and implementation of certain measures, EPA recognizes facilities will most likely implement IST/ISD when an IST/ ISD’s net cost is less than a passive measure’s cost. EPA assumes owners and operators will likely explore specific benefits to their facility when making decisions and expects the evaluation to consider several factors, such as operating and maintenance costs, productivity improvements, safety improvements, and capital / facility reduced losses.
EPA states that IST is a relative concept dependent on the hazard, the technology, and the facility. Therefore, EPA is requiring facilities to only consider IST as a possibility for addressing hazards rather than requiring ISTs be implemented.
EPA believes that the performance-based nature of the STAA requirements and the overall RMP rule allow facility owners and operators the discretion to determine which IST / ISDs and passive, active, and procedural safeguard measures work best for their particular chemical use, process, or facility and for protecting the community potentially affected.
For those facilities that have not considered adopting any IST or have only done so in limited fashion, EPA believes that there is value in requiring facilities with regulated substances to evaluate whether they can improve risk management of current hazards through potential implementation of ISTs or risk management measures that are more robust and reliable than ones currently in use at the facility.
For those facilities that have already considered IST, EPA believes facilities should re-evaluate whether any improvements in hazard or risk reduction can be made.
In principle, the STAA eliminates or minimizes the opportunities for a chemical release because identification and implementation of ‘‘safer’’ technologies and alternatives, should result in a hazard or risk reduction for a particular RMP chemical or process.
EPA recognizes that neither IST nor other procedural, active, or passive measures alone will eliminate all hazards or risks and that reliance on a combination of risk reduction measures will probably be needed.
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Disclaimer: This PT Note provides Primatech’s interpretation of regulatory requirements. The actual regulatory requirements can be found at: https://www.epa.gov/rmp
