RMP Safer Technology and Alternatives Analysis (STAA)

Why Is a Safer Technology and Alternatives Analysis Necessary?

In 2016, the EPA proposed to amend the RMP rule by requiring the analysis of safer technology and alternatives as part of the already-required process hazard analysis (PHA) conducted every five years by Program 3 facilities. A safer technology and alternative analysis (STAA) considers a hierarchy of controls to reduce process hazards, consisting of inherent, passive, active and procedural controls. STAA can be applied from conceptual design through to decommissioning of a process.

Why Work With Cognascents’ Hazard Assessment Team?

Cognascents incorporates STAA into their PHAs by evaluating opportunities to substitute, minimize, moderate or simplify the process being risk-assessed to eliminate identified hazards. Our engineers are well-versed in applying inherently safer design (ISD) to new and existing processes to provide guidance to the PHA team when developing recommendations to safeguard vulnerabilities uncovered by the STAA.

We are capable of going one step further with a STAA by also conducting commercial and technical feasibility studies of the proposed inherently safer technologies (IST) or alternative designs. We can help clients determine whether it is reasonable to implement ISD or IST from a business perspective.

LOPA (Layers of Protection Analysis)

STAA can also include layers of protection analysis (LOPA). All of our facilitators are trained and experienced in leading a PHA team through a LOPA. A LOPA helps meet the spirit of STAA through semi-quantitative evaluation of identified hazard scenarios using likelihood and probability of failure on demand values for initiating events and independent protection layers (IPLs) along with conditional modifiers to better develop the consequence.

 Contact Cognascents to help you plan and price your next PHA to include a safer technology and alternatives analysis and/or LOPA.