What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format?
The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning responsibility for that implementation (58 FR 54196; October 20, 1993). The extent of the management system will depend on the size and complexity of the source. At many small sources, the appointment of a person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements, as required under 40 CFR §68.15(b), may satisfy the management system requirement. For larger sources, separate divisions may be responsible for overseeing different elements of the risk management program.
The management system should document the integration of your operations. For example, if process equipment is changed, process safety information must also be changed, training may need to be revised, and both operators and maintenance staff must be informed. Some basic questions you should ask yourself are: Do you (corporate) know who is in charge of implementation? Do your employees involved in implementation understand what their roles are, whom they report to, and whom they need to talk to when they make changes or problems arise? The management system is a way to ensure that each department involved in the process understands its responsibilities and who should be contacted when changes or other concerns arise.
There is no standard format for the management system. It should be designed to ensure that each person knows what his/her responsibilities are and the lines of authority. This system can be documented by an organization chart, but other methods can be used as well. The rule provides you with the flexibility to design and manage your management system in whatever way works best for you. You are not required to submit the management system to EPA. EPA has developed general guidance on RMP implementation that discusses management systems in further detail (see Chapter 5 of the General Guidance On Risk Management Programs For Chemical Accident Prevention (40 CFR Part 68). In addition, you may want to consider guidance produced by private parties, such as the Center for Chemical Process Safety (CCPS) who has a Process Safety Documentation guidebook for sale that might be helpful if your management system is complex. (To order: call 1-800-AICHEME).