Risk Management:
The next wave for the use of EDMS

by Rory Moran

The big picture

Are you looking to harness your EDMS technology to solve a real line of business problem? Well, look no more. Very similar to the OSHA 1910.119 legislation of the early 1990’s, dealing with Process Safety Management (PSM) for safety in the workplace; there is a new piece of legislation that can have an even farther reaching impact. The new Risk Management Program (RMP) legislation requires more comprehensive documentation of your safety and environmental programs as it looks at your programs for both "inside and outside the fence" of your facility.

This time it is not OSHA but rather the Environmental Protection Agency (EPA) that has required applicable companies to have documented Risk Management Programs for Chemical Accidental Release Prevention. What is fundamentally different about this legislation is that it is more "proactive" in terms of its’ reporting requirements. Rather than having a program in place waiting for a visit from OSHA, RMP obligates you to file a plan with the EPA and puts the facility on record as to its’ status and the fact there is a Risk Management Plan in place. This is a very significant change from the way business has been done in the past.

Born of the Clean Air Act Amendments of 1990, the Risk Management legislation (40 CFR Part 68), was finalized in 1996 with some deadlines that are lurking just around the corner. It requires regulated industries to be in full compliance in a three year period. Unlike OSHA 1910, the operative word is "full compliance". Thus, it does not allow for a phase in schedule but again expects you to be in full compliance by June, 1999. Even though this sounds like enough time, ask your PSM managers how long it took them to get in compliance with the OSHA1910.119 regulations.

Most companies that have PSM facilities are affected by this legislation but many facilities that are not covered by PSM, may be covered by RMP.

What facilities are covered?

All facilities that handle, process or package an appreciable quantity of hazardous chemicals are covered. This includes a list of some 77 toxic and 63 flammable materials. If your facility contains certain threshold quantities of these chemicals, then you need to have a Risk Management plan for your facility.

What needs to be done now?

Each facility needs to review their existing production processes and determine if they are an RMP facility. The next step is to perform hazard assessments determining the "worst case scenario" associated with a potential chemical release. This will enable you to determine if 1) you are an RMP facility and 2) what are your reporting requirements. There are three different program levels defined in the legislation that help define what your reporting requirements might be. Most PSM facilities are Program 3 facilities. Exhibit I helps define which program level you might fit in.

What are the reporting requirements?

RMP facilities may be required to have the following contents of their Risk Management Program:

1. Hazard Assessments
1. Management Program
1. Prevention Program
1. Emergency Response Program
1. Risk Management Plan Elements

The key to each of these is the great emphasis on the need for a documented program with documented lines of authority. Just as important, this information needs to be submitted to the EPA and updated every 5 years or whenever 1) a new substance or process is added or determined to be above the designated threshold level or 2) a new hazard assessment and a revised offsite consequence analysis is performed. Any changes such as this would require a revised plan to be submitted within six months of the change. Therefore, this is a very dynamic document which will require constant attention and revision control.

Addressed in the Prevention Plan Reporting part of the Risk Management Program are all the elements of OSHA 1910.119 for Process Safety Management, including the very important Management of Change (MOC) provision. This specifically deals with how you handle the change process within your facility and the various approvals required prior to changes being implemented. A PSM and RMP compliance facility should have one MOC process that includes a review of all of the relevant documentation. If you are a Program 3 RMP facility, you are required to assert that you are fully compliant with PSM as well. Because of the stringent documentation and reporting requirements, one master set of documents should be maintained and used for operations, engineering, and regulatory compliance.

How do I best harness my EDMS technology to address this issue?

Now more then ever before, there is an even greater need to efficiently manage documents. Process Information, Operating and Maintenance Procedures, and Safety and Environmental Policies and Procedures must be documented, controlled, used, and maintained. The RMP regulation will require more facilities to do so. The reality is that processes and inventory levels of covered substance change regularly and the changes affect these documents. Therefore, there will be an even greater need to bring some basic EDMS functionality to this program, such as:

• Version Control
• Quick search/ retrieval
• Audit trail for documents
• Security of documents
• Change control notification

Even more importantly, this new legislation emphasizes "the outside the fence" users of these materials. Documentation dealing with your Emergency Response Programs and access to such by local authorities, hospitals, and other users, stretch the limits of your people/resources as never before.

The use of an Internet/Intranet based EDMS technology which would allow access via a Web browser to certain documents for use by the public domain (as well as your own remote employees) would be an optimal tool to address this dilemma.

Finally, managing the change process is key to a demonstrable return on your investment. An effective MOC process must also be efficient. Reducing the cycle time associated with the proposed changes to drawings, procedures and related documentation can provide substantial savings to your organization and result in a safer facility for both your workers and the surrounding community.

What do I need to do now?

First and foremost, find out where your EH&S managers are in their schedule with respect to full compliance with RMP by the June, 1999 deadline.

Second, think about what will happen after June, 1999. Many companies find that initial implementation of regulatory motivated documentation is much easier than ongoing maintenance of it. Compliance with these regulations has to become a way of life, not a one time event.

Third, use your existing PSM program as the starting point for your RMP program. The software tools you have in place to provide your employees access to documents, edit documents, establish version control and provide an audit trail for these documents and most importantly, control the Management of Change process are all key elements within your current PSM program that can be used for Risk Management as well. The only distinctive difference will be the "public domain" issue which presents a new twist to the solution deployed. Be aggressive about involving the end users in the development of both the documentation and the technology to maintain it.

Finally, do not try reinventing the wheel. Leverage the technology that is out there and look for a system integrator/development house that knows the subject matter, has experience in deploying successful solutions like this in both the EDMS and RMP/PSM arenas and can customize the software (if required) to maximize the benefit within your organization. To the extent possible, build the technology around your organization, not vice versa. The less a system "shocks" your organization, the more likely it is to be successful.

Summary

The business need is out there and indeed upon us. The EDMS technology provides the key functionality we need and with the advent of this same functionality over the Internet, it is simply a matter of putting the pieces together. Don’t delay, June, 1999 is just around the corner.

Rory Moran is one of the Managing Partners for M&H Enterprises in Houston, Tx. For over 20 years, M&H has been furnishing a wide array of engineering services throughout North America. The company has also provided EDMS based solutions to a number of clients in the chemical/petrochemical and process manufacturing industries focusing specifically on regulatory compliance and quality systems.