RMP Operating Procedure Development

The Clean Air Act Amendment of 1990, Section 112(r), required the EPA to issue regulations and guidance to prevent accidents and releases at facilities producing, handling, processing, distributing, or storing certain chemicals. The Chemical Accident Prevention Provisions of Section 112(r) require these facilities to develop, implement, and sustain a Risk Management Plan (RMP).

Per the RMP Rule, the owner or operator of each facility “shall prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process.”

Cognascents engineers are available to work with company personnel to generate operating procedures that address the following:
  • Initial startup
  • Normal operations
  • Temporary operations
  • Emergency shutdown and operations
  • Normal shutdown
  • Startup following a normal emergency shutdown or a major change that requires a hazard review
  • Consequences of deviations and steps required to correct or avoid deviations
  • Equipment inspections

Cognascents has worked with many of the major oil, gas, and chemical companies to develop operating procedures from scratch or to update operating procedures after a major design change. Cognascents has also worked with small companies to develop operating procedures for processes that have grown in the last decade and are now covered by RMP.

Cognascents engineers are multi-disciplined engineers with experience across the oil, gas, and chemicals industries. Cognascents has worked with clients through regulatory scrutiny and knows what “compliance” looks like. Cognascents prides itself on being accessible to all and affordable to all, no matter a company’s size and status.

Contact Cognascents to help you scope out and price your next RMP operating procedure development effort. We are here to serve.