The EPA Risk Management Program ― Part 2
Program Levels
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).
In the first post in this series, the overall structure of the EPA Risk Management Program (RMP) was introduced, and its relationship to OSHA’s Process Safety Management (PSM) regulation and the CCPS guidance was discussed. One feature of the RMP that is often misunderstood is the use of program levels.
Neither OSHA nor CCPS uses program levels. Program levels are a feature unique to the EPA RMP rule; they reflect EPA’s risk-based approach to regulating chemical hazards with potential offsite consequences.
Purpose of Program Levels
The EPA RMP applies to a wide range of facilities, from small installations with limited public exposure to large, complex sites with the potential for significant offsite impacts. Rather than applying the same prevention requirements to all covered facilities, EPA uses program levels to scale regulatory expectations.
In simple terms, program levels are intended to answer two questions:
How severe could the offsite consequences of a release be?
How complex is the covered process and its operating environment?
