The EPA Risk Management Program ― Part 1

Overview

Many of the posts at this site have discussed the process safety standards from OSHA (the United States Occupational Safety and Health Administration) and the guidance from the CCPS (Center for Chemical Process Safety).

Another U.S. process safety regulation is the Risk Management Program from the EPA (Environmental Protection Agency). This post is the first in a series that describes the RMP and how it fits into the process safety management discipline. The RMP is compared with the OSHA regulation and the non-legally binding CCPS guidance.

Rules, Regulations, Standards and Guidance

One area of potential confusion is to do with the words rule, regulation and standard. The EPA tends to use ‘rule’ whereas OSHA uses ‘regulation’. From a legal point of view, the two terms are equivalent. Both are enforceable, although penalties may differ. The agencies use different words due to history and culture, not legal distinction.

Less formally, the EPA and OSHA approach risk differently. The EPA is more concerned with the impact of incidents on the public and the environment. OSHA, on the other hand, focuses on worker safety. There is, of course, considerable overlap between the two ― these boundaries are far from rigid. But they do reflect differences in attitude and approach.