RMP Awareness Training and RMP Training Program 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 ensure each employee presently involved in operating a process, and each employee before being involved in operating a new process, shall be trained in an overview of the process and in the operating procedures. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks. In addition, “refresher training shall be provided at least every three years, and more if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process.”

Cognascents helps clients with RMP training by providing a general RMP awareness training workshop to all employees regardless of whether they are an operator or not. Cognascents also helps clients develop and implement facility-specific training focused on achieving compliance with the above RMP Rule requirements.

RMP Awareness Training

Cognascents offers RMP awareness training to anyone wanting to become more familiar with the history, background, requirements, and implementation approaches to the RMP Rule. Cognascents provides a general overview of the following elements:
 1.   History to the RMP Rule
 2.   Definitions
 3.   Applicability
 4.   General requirements
 5.   Hazard assessment requirements
    a. Offsite consequence analysis parameters
    b. Worst-case release scenario analysis
    c. Alternative release scenario analysis
    d. Defining offsite impacts
    e. Five-year accident history
 6.   Prevention program requirements
    a. Process safety information
    b. Process hazard analysis
    c. Operating procedures
    d. Training
    e. Mechanical integrity
    f.  Management of change
    g. Pre-startup review
    h. Compliance audits
    i.  Incident investigation
    j.  Employee participation
    k. Hot work permit
    l.  Contractors
 7.   Emergency response requirements
 8.   Regulated substances for accidental release prevention
    a. Threshold determination
    b. List of substances
 9.   Risk management plan requirements
 10.  Other requirements
    a. Recordkeeping
    b. Availability of information to the public

RMP Facility-Specific Training

Cognascents also helps clients develop and implement RMP facility-specific training. This training is focused on achieving and sustaining compliance with the RMP rule. RMP facility-specific training is tailored to site-specific operating procedures and is accompanied by competency assessment tools, both for a new employee as well as for an employee receiving refresher training.

At a minimum the training will address the following:
 1.  Process overview
 2.  Safety and health hazards
 3.  Initial startup
 4.  Normal operations
 5.  Temporary operations
 6.  Emergency shutdown and operations
 7.  Normal shutdown
 8.  Startup following a normal emergency shutdown or a major change that requires a
      hazard review

 9.  Consequences of deviations and steps required to correct or avoid deviations
 10. Equipment inspections

Cognascents has worked with many of the major oil, gas, and chemical companies to develop training modules from scratch or to update existing training modules after a major design change. Cognascents has also worked with small companies to develop training modules 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 training effort. We are here to serve.