Letters: May 2018 | AIChE

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Letters: May 2018


EPA’s Role in Process Safety

I very much appreciate the article “Committing to Safety Awareness” (March 2018, p. 13), which reviewed the March AIChE Journal Perspective, “Safety Awareness: A Chemical Engineering Imperative,” by Robert Davidson. Safety awareness is critically important for chemical engineers beginning at the undergraduate level and throughout their careers.

Although the U.S. Environmental Protection Agency (EPA) was addressed with respect to the U.S. environmental movement, I was rather disappointed that Mr. Davidson failed to acknowledge EPA’s role in catastrophic chemical accident prevention, preparedness, and response. EPA’s Risk Management Program (RMP) for the prevention of chemical accidents is complementary to the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) standard. OSHA’s PSM standard works to protect workers from catastrophic chemical accidents; EPA’s RMP works to protect the public and the environment. While both regulations have PSM at their core, the RMP has two fundamental additional requirements of importance to process safety: hazards analysis (including worst-case scenarios) and development of an emergency response program. Further, the RMP prepared by a covered facility is shared with State Emergency Response Commissions (SERCs) and Local Emergency Planning...

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