| Contributor:
Sharon Arteaga
Business Title: Senior Regulatory Analyst Contact Information: Biography: Sharon Arteaga is a senior regulatory analyst with Burns & McDonnell. She provides multimedia environmental compliance, permitting under the Clean Air and Clean Water Acts, and training services to industrial and governmental clients throughout the United States. She also serves as a consultant to divisions within the company in environmental regulatory matters. Her industry experience includes grain handling and food processing, foundry operations, natural gas processing and transporting, chemical manufacture and formulation, petroleum and related industries, metal fabrication and painting, and public water and electric utilities. A graduate of the University of Missouri, Ms. Arteaga has over 20 years of experience in the environmental field. She has supervised teams of engineers and scientists responsible for major environmental assessments, multimedia permit acquisition, and compliance |
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| Title
of Presentation: PSM and RMP: Risk Planning by the Alphabet
Authors: Sharon Arteaga and Ken Grist
Key Words: Process Safety Management, PSM, Risk Management Rule, RMP, Plans Abstract: The Occupational Health and Safety Act Process Safety Management (PSM) rule and the Environmental Protection Agency Risk Management Plan rule requirements overlap significantly. Nowhere is this more evident than during the implementation of Risk Management Plans (RMP) developed for industrial and public entities. In both industry and public facilities such as power plants, wastewater treatment plants and other utilities, safety and health administration and the management of environmental issues is often the purview of separate groups within the company or utility. Many environmental and safety issues have overlapping elements which can make administering each program a challenge when there is little communication and sometimes little cooperation between the groups. With the OSHA and EPA risk management rules, there is even more overlap. Some say communication and cooperation between the agencies during development of the rules was less than it should have been. In order to prevent reinventing, and maybe even redesigning the wheel, it helps to understand the requirements of both rules. Potential problems with consistency and unnecessarily repetitive plan provisions were noted during the development of RMP plans for many industries, but the problems themselves have showed up in the implementation phase. In one instance an unfortunate entity had the opportunity to test out their plan when the RMP chemical was first delivered to their site. The exercise was instructive and there were no lasting consequences, but problems with the plan were indicated in sharp relief. That industry is in the process of replanning with better communication in mind. |