Update to the EPA RMP Rule. Part 1: Natural Hazards

We have completed our review of OSHA’s proposed changes to its process safety standard. Our discussions and analyses are provided in the book The OSHA Process Safety Standard: The 30-Year Update.

The EPA (Environmental Protection Agency) is going through a similar update process, as described in the post Updates to the RMP Rule. This is the first post in a series that examines and discusses the proposed updates. The topic is Natural Hazards. The pertinent section of their proposed update is shown below.

Prevention Program (Subparts C and D)
Natural hazards¹

(1) Adding amplifying regulatory text to emphasize that natural hazards (including those that result from climate change) and loss of power are among the hazards that must be addressed in Program 2 hazard reviews and Program 3² process hazard analyses.

Natural Hazards

The EPA states that it is requesting comments on the following.

• The Agency’s proposed approach.

• Whether EPA should develop additional guidance for assessing natural hazards.

• Natural hazard resources such as databases, checklists, or narrative discussions, as well as commenters’ recommendations for regional versus national, or sector-specific guidance.

• Whether to specify geographic areas most at risk from climate or other natural events by adopting the list of areas exposed to heightened risk of wildfire, flooding, storm surge, or coastal flooding and if this approach would simplify implementation.

• If the Agency should require sources in areas exposed to heightened risk of wildfire, flooding, storm surge, coastal flooding, or earthquake, to conduct hazard evaluations associated with climate or earthquake as a minimum, while also requiring all sources to consider the potential for natural hazards unrelated to climate or earthquake in their specific locations.

Some thoughts on these items are provided below.

Proposed Approach

The proposed approach is based on the assumption that climate change is happening, and that it is severe enough to affect the safety of process and energy facilities.

The catch is that the Agency’s approach does not address the fact that climate change is not a single event — it is a process. The impact of a changing climate will become increasingly severe over the years. For example, sea level rise is currently a relatively minor problem for facilities operating on the U.S. Gulf Coast of Mexico. Twenty years from now it could be much more serious. To further complicate matters, climate change does not necessarily equate to ‘global warming’. If the Atlantic Gulf Stream, for example, were to slow down or change course, temperatures in western Europe may actually fall. There is a lot of uncertainty.