Incident Investigation Programs

The Incident Investigation element of PSM and RMP programs are of particular interest to the EPA, since the potential threat during an incident or release could be off site and involve neighborhoods and larger areas.

In this regard, it is important to note that the regulators say that incidents must be reported immediately – which the EPA interprets as within 15 minutes. When an incident occurs, it is important to have a plan in place which can evaluate whether or not the release will be either (1) over 100 lbs in 24 hours, (2) a person will be injured or hospitalized or (3) whether the release will go off-site. If any of these three are possible, then the release must be reported to EPA’s National Response Center (NRC), State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and the local Fire Department(s) within 15 minutes. Serious fines are levied for not taking these actions.

With these things in mind, the Incident Investigation requirement in PSM and RMP must include the following:

1. A procedure (Incident Investigation Plan) is in place for investigating releases OR “near misses”.
2. This procedure needs to:
a. Define what constitutes and incident and a near miss
b. Create a structure for performing the investigation (a team and procedures to use)
c. Identify methods for addressing any recommendations from the incident
d. Establish methods of communicating the results of the incident

Note that having an Incident Investigation Plan in place and implemented is a requirement of both OSHA PSM and EPA RMP regulations.

For further information regarding Incident Investigation Programs, investigating incidents, and/or other PSM related questions, please contact CECI.