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Keywords:

  • near miss;
  • RMP;
  • incidents;
  • regulation;
  • regulator;
  • PSM

Near miss incidents include those releases and/or fires that do not result in significant employee injury or costs. In many cases there are federal reporting requirements that include reports to the National Response Center. Loss of containment releases are often near misses for catastrophic incidents and provide evidence of process safety program weaknesses. Facilities have an interest in conducting incident investigations to find root causes, lessons learned, and make safety improvements. Small sites often do not have the expertise to conduct good investigations while some large sites may tend to blame operator error rather than admit management system errors or process design issues. This article explains 2002 amendments of the Delaware requirement to report releases. The amendment adds the reporting of flammable gas releases and expands the existing written follow up report requirements to explain the “facts and circumstances leading to the release and the measures proposed to prevent the future releases and remedy any deficiencies in the prevention program.” Having this “public” examination of near miss investigations puts pressure on both industry and our regulatory program to seek root causes and make practical improvements in site process safety programs—without adding any substantial regulatory burden to industry. © 2013 American Institute of Chemical Engineers Process Saf Prog 32: 328–331, 2013