EPA to Require Root Cause Analysis in RMP Required Investigations
The EPA announced in December their intention to finalize a new r Risk management Plan rule for facilities with highly hazardous chemicals. Of interest to readers of this blog, the new proposal for incident investigations requires root cause analysis using a recognized method.
Here is the proposed language:
(a) The owner or operator shall investigate each incident that:
- Resulted in a catastrophic release (including when the affected process is decommissioned or destroyed following, or as the result of, an incident); or
- Could reasonably have resulted in a catastrophic release (i.e., was a near miss).
(b) A report shall be prepared at the conclusion of the investigation. The report shall be completed within 12 months of the incident, unless the implementing agency approves, in writing, an extension of time. The report shall include:
- Date, time, and location of incident;
- A description of the incident, inchronological order, providing all relevant facts;
- The name and amount of the regulated substance involved in the release (e.g., fire, explosion, toxic gas loss of containment) or near miss and the duration of the event;
- The consequences, if any, of the incident including, but not limited to: injuries, fatalities, the number of people evacuated, the number of people sheltered in place, and the impact on the environment;
- Emergency response actions taken;
- The 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; and
- Any recommendations resulting from the investigation and a schedule for addressing them.
With the new administrations halt on new regulations, I’m not sure what will happen with this modification to an existing rule … so keep an eye out for the publication in the Code of Federal Regulations.
One last note if you were wondering … TapRooT® Root Cause Analysis is a recognized method.