PT Notes
EPA RMP Rule 2024 Amendments - STAA Technology Transfer
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 rule requires that Program 3 Process hazard Analysis address STAA, which involves the application of the hierarchy of controls for process safeguards.
EPA is requiring that basic information on IST, facility information, categories of safer design identified and implemented and causal factor for initiating safer design implementation be provided in the RMP submission. Specifically, the owner or operator shall provide:
Inherently safer technology or design measures implemented since the last PHA, if any, and the technology category (substitution, minimization, simplification and/or moderation).
These technology transfer provisions apply to all facilities required to conduct any component of STAA (evaluation or practicability) under the amended RMP rule. This reporting is also voluntary for all other facilities, including deregistered facilities, by which EPA expects to capture useful information about how some facilities, on their own accord, choose to make their processes safer.
EPA intends for this provision not to be a cumbersome exercise, but rather one that is based on information facilities likely already have. The intended fields of check boxes, dates, and numbers that summarize STAA activities for this provision will help facilitate data analysis for EPA to compile and make available for other industries to identify safer alternatives.
EPA believes that the primary utility of STAA information for the public is to identify whether facilities are implementing IST and the nature of that change. In addition to information exchanged through an information request under the provision for the availability of information to the public, EPA encourages facilities to provide information about any IST or other safer technology alternatives that the facility is using, or could be using, at a public meeting forum or any other community outreach opportunity.
EPA believes that facilities should expect that a community wants to discuss hazards and risks associated with their chemical processes. Effective communication with the public can be an opportunity to develop robust relationships with communities, and trust is gained when considering the needs and challenges facing those potentially affected by accidents.
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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
