Uh, Oh Series: Changes to EPA Process Safety Standards
In Part IV of the Uh, Oh… series, Bill Lape provides advice on Rule Changes to 40 CFR 68.83 (EPA 40 CFR Part 68 Subpart D, 2024). He then follows with compliance strategies to meet new process safety standards for employees. 40 CFR Part 68, Subpart D, outlines the Program 3 Prevention Program for chemical accident prevention, requiring facilities to implement measures like process safety information compilation, process hazard analysis, and emergency response coordination, aiming to protect communities from chemical accidents.
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About the Author: Bill Lape, CARO, CIRO, CRST, is the Refrigerating Engineers and Technicians Association executive vice president and project director for the Risk Management Group for SCS Engineers Tracer Environmental Group.
Key Elements of 40 CFR Part 68, Subpart D (Program 3 Prevention Program):
Process Safety Information: The owner or operator must compile and maintain written process safety information to understand the hazards of the process, including information on the regulated substances, the technology, and the equipment.
Process Hazard Analysis (PHA): A PHA must be conducted to identify and evaluate potential hazards, including natural hazards and power loss, and develop safety recommendations.
Operating Procedures: Establish and maintain clear, readily accessible operating procedures for the process, ensuring they reflect current practices and are reviewed and updated as needed.
Training: Provide adequate training to employees on the process and its hazards, including emergency response procedures.
Mechanical Integrity: Implement a program to ensure the mechanical integrity of equipment, including regular inspections and maintenance.
Management of Change: Establish a system to manage changes to the process, equipment, or procedures, ensuring that changes are evaluated for potential hazards and implemented safely.
Pre-Startup Safety Review: Conduct a pre-startup safety review to ensure that all safety measures are in place before starting up a new or modified process.
Incident Investigation: Investigate all incidents that have the potential for catastrophic consequences, identifying root causes and implementing corrective actions.
Emergency Response Coordination: Coordinate with local emergency planning and response organizations to ensure effective emergency response planning and response.
Emergency Response Program: Develop and maintain an emergency response program that addresses potential chemical accidents, including procedures for evacuation, containment, and cleanup.
Compliance Audits: Conduct periodic compliance audits to ensure that the prevention program is being implemented effectively.
Third-Party Audits: Consider conducting third-party audits to provide an independent assessment of the prevention program.
Employee Participation: Ensure that employees are involved in the development and implementation of the prevention program.
Documentation: Maintain thorough documentation of all aspects of the prevention program, including PHAs, operating procedures, training records, and incident investigations.
Public Availability: Ensure that certain information, such as the five-year accident history, is made available to the public in accordance with EPA requirements.
