PT Notes
EPA RMP Rule 2024 Amendments - Root Cause Analysis
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 adds the following requirements for Incident Investigation for Program 2 and 3 processes:
The owner or operator shall ensure the following are addressed for incidents that meet the accident history reporting requirements of the RMP rule:
The report shall be completed within 12 months of the incident, unless the implementing agency approves, in writing, to an extension of time.
The report shall include factors that contributed to the incident, including the initiating event, direct and indirect contributing factors, and root causes. Root causes shall be determined by conducting an analysis for each incident using a recognized method.
The amended RMP rule defines Root Cause as:
A fundamental, underlying, system-related reason why an incident occurred that identifies a correctable failure(s) in management systems, and if applicable, in process design.
EPA recognizes that an incident may have more than one root cause. EPA is adopting the CCPS definition of root cause due to its wide use among the process safety industry. EPA is also adding process design to the definition because process design points to a specific management system failure that may offer facilities an opportunity to design their process more safely.
EPA believes that requiring root cause analyses after RMP-reportable accidents, and including root cause information in incident investigation reports, is vital for understanding the nature of these events and how they may occur.
EPA performed an analysis of its RMP accident reporting data and identified repeat accidents at facilities within the same process. EPA believes that the result of the analysis demonstrates that, among facilities reporting accidents, facilities that reported one accident often have a history of multiple accidents, thus indicating a failure to properly address circumstances leading to subsequent accidents. These accidents may have been preventable if root cause analyses had been required. EPA believes multiple accidents result, in part, from a failure to thoroughly investigate and learn from prior accidents.
EPA notes that the amended RMP rule does not require facilities to use a specific root cause analysis method, select from a predetermined list of root causes, or force-fit investigation findings into an inappropriate category.
EPA believes these provisions are most appropriate for Program 2 and 3 processes because facilities with these processes have RMP-reportable accidents more often and pose a greater risk to the public as their worst-case scenario distance would affect public receptors. Program 1 processes only account for few of the total RMP-reportable accidents, do not have recent accident history with specific offsite consequences, and have no public receptors within the worst-case release scenario distance.
While it is true that most RMP-reportable accidents occur at Program 3 processes, EPA decided that there was little justification for limiting the root cause requirements to only Program 3 processes, because serious accidents also occur at Program 2 processes.
Also, EPA notes that some of the accidents at Program 2 processes occur at publicly-owned water and wastewater treatment facilities that are not in Program 3 only because they are not located in a State with an OSHA-approved State Plan. While State and local government employees at facilities in States with OSHA-approved State Plans must comply with State Plan requirements that are at least as effective as the Federal OSHA PSM standard, State and local government employees at facilities in States under Federal OSHA authority are not covered by the OSHA PSM standard or any equivalent measures. This situation results in regulated processes at these sources being placed in Program 2, even though the processes generally pose the same risk as similar processes at publicly owned water or wastewater treatment processes that are located at sources in States with an OSHA State Plan.
EPA recommends that owners and operators consult available literature on root cause investigation methods to select those appropriate for their facility and processes. For example, CCPS has published Guidelines for Investigating Process Safety Incidents, which provides extensive guidance on incident investigations, near miss identification, root cause analysis, and other related topics.
EPA believes that the 12-month timeframe for reporting provides a reasonable amount of time to conduct most investigations, while also ensuring that investigation findings are available relatively quickly in order to assist in preventing future incidents. For very complex incident investigations that cannot be completed within 12 months, EPA is allowing an extension of time if the implementing agency approves such an extension in writing. EPA encourages owners and operators to complete incident investigations as soon as practicable and believes that 12 months is typically long enough to complete even complex incident investigations. However, EPA has provided flexibility for facilities to request more time to complete investigations when they consult with their implementing agency and receive written approval for an extension.
EPA also emphasizes the importance of implementing recommendations as soon as possible after completing an incident investigation to prevent future similar incidents.
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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
