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In response, in part, to the EO, the EPA has:
- Issued a request for information (RFI) seeking public comment on updating its risk management program (RMP) regulation, and a notice of proposed rulemaking is being prepared. The Agency is looking for specific feedback on whether the list of RMP-regulated substances should be modified by adding other substances, such as ammonium nitrate.
- Initiated a Small Business Advocacy Review (SBAR) Panel that will focus on the Agency’s development of a rule that proposes to modify the current RMP regulation to reduce the likelihood of accidental releases of toxic and flammable substances at chemical facilities, and improve emergency response when those releases occur.
- Initiated an enforcement program to identify facilities that are subject to the Risk Management Program but were not complying with it.
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‘Alert’ Pushes IST
The EPA and OSHA recently issued a joint “alert” to encourage the use of inherently safer technologies (IST) at chemical facilities. The Chemical Safety Alert: Safer Technology and Alternatives is intended to lay the groundwork for a future guidance document by introducing safer technology concepts and general approaches.
According to the Alert, the first choice for managing chemical hazards and risks at a facility is the use of IST or inherently safer design (ISD) through a hierarchy of controls, with the first preference being avoiding hazards by using non- or less-hazardous substances, minimizing the quantity of hazardous substances, or modifying processes to eliminate or reduce the likelihood or severity of incidents.
So, for example, you could replace gaseous chlorine with hypochlorite or replace a flammable solvent with a water-based system. An example offered for reducing or eliminating a hazard through a process change is converting an anhydrous ammonia refrigeration system to a system that uses a less toxic refrigerant such as glycol and ammonia.
If replacing a hazardous substance is not an option, the EPA and OSHA suggest in the Alert that you reduce the quantity of hazardous substances stored as feed or product inventory. One way to do that would be to implement “just-in-time” deliveries of the feed or product and use smaller containers to supply a process.
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How to Begin
If you choose to follow this advice from the EPA and OSHA, you need to begin with two very basic steps:
- Know your chemicals. You must understand all of the physical and chemical properties of all of the substances at your facility. Know the reactions each chemical would have if released or mixed with something else, or what would happen with that substance in case of a fire.
- Know your processes. You must understand all the ways in which substances at your facility are handled and/or processed, even the ones that just sit in a warehouse temporarily. For instance, what would happen if the power goes out, or if a compressor generates too much pressure, or if a forklift punctures a container?
What’s Next?
According to the EPA, there will be more guidance with more practical details and examples to help facility managers control hazards and reduce risks. However voluntary this type of guidance is now, because of the rising number of explosions at chemical facilities, there will be a growing call for agencies to require IST and ISD by regulations. The first step for the EPA may be incorporating IST in changes to Risk Management Program regulations.