The Changing Tide of U.S. Process Safety/Risk Management Regulations - How CCPS Risk Based Process Safety and Vision 20/20 Concepts Can Harmonize Future Requirements

摘要

Over the past two decades there have been numerous industrial accidents which have brought the effectiveness of Occupational and Health Administration's (OSHA's) Process Safety Management (PSM) Standard and Environmental Protection Agency's (EPA's) Accidental Release Risk Management Planning (RMP) Rule under review. On August 1, 2013, President Obama, largely in response to the explosion at the West Fertilizer Company in Texas, signed an Executive Order mandating that the relevant agencies "improve the safety and security of the chemical industry in the United States".1 As a result, both OSHA and EPA have recently requested information on sweeping new proposed changes for both the PSM and RMP regulations. This paper will examine OSHA's and EPA's proposed changes in the context of how they can be harmonized and streamlined by utilizing the basic concepts of the Center for Chemical Process Safety (CCPS) Risk Based Process Safety (RBPS) guidelines and CCPS Vision 20/20 themes. As such, the paper will outline a suggested path forward for U.S. regulations that incorporate the basic CCPS Vision 20/20 tenets to establish rules that are harmonized with leading generally accepted global Process Safety practices.