Every EPA Risk Management Plan (RMP) must be updated at least once every five years or sooner if specified regulatory (see 40 CFR 68.190(b)) mandated change conditions are trigged.
An update must include all nine sections of your RMP.
A Five-Year Update usually consists of these components:
- Hazard Assessment Update
- Process Hazard Analysis (PHA) or Hazard Review (HR) Update
- Certification and submittal of the RMP to the Correct Agency
We suggest you include as part of the RMP update planning process a review of the information management tools utilized to support the previous submission. Information technology changes quickly, so to ensure you are using best practices that will last through the next decade review the risk reduction information technology supporting the process.
PHA and Hazard Review Updates
Process Hazard Analysis or Hazard Review Five Year Revalidation is often aligned to the Five-Year Update of the RMP. This is the right time to engage a Sharrix Specialty Services Partner to provide engineering support, methodology training, facilitation to review hazards. Our partners have the industry-specific knowledge along with a fresh set of eyes and ears to refresh your risk studies. These studies include;
- Hazard and Operability (HAZOP)
- Layer of Protection Analysis (LOPA)
- What-If and Checklist Analysis (What If)
As organizations prepare to refresh these studies we often get selected to update the information management system documenting the studies. If the last RMP studies were recorded with a desktop constrained PHA software product, the Five-year update is a perfect time to evaluate new alternatives.
Sharrix offers the ability to quickly import historical study data from common desktop products like PHAWorks®, LEADER™, PHA Pro®, and others. Former users of these desktop systems tell us that desktop software makes it difficult to track risk reduction recommendations to completion, connect to related engineering workflows, integrate with equipment, incident, MOC, or process related master data.
Information trapped in desktop tools are no longer acceptable to support collaboration. Leading organizations want to improve cross-functional teamwork, standardize risk language across various studies and improve visibility to reduce risk.
If you want to learn more about how Sharrix can help you with your RMP update and supporting information management systems, sign up for a free trial or contact us.
