Frequent Questions

What Incident Investigations and Root Cause Analysis requirements are included in the final rule?

The final rule requires additional reporting elements to investigations that are required after any incident that resulted in or could reasonably have resulted in a catastrophic release.  The facility must identify the fundamental reason (“root cause analysis”) for the incident, and prepare a report within 12 months of the incident that includes consequences of the accident and any emergency response actions taken.

EPA modified the proposed definition of “root cause” to eliminate the phrase “that identifies a correctable failure(s) in management of systems” so there would be no implication that all incidents include a correctable management system failure.

Also, in the final rule, EPA clarifies which near-miss incidents (i.e., incidents that could reasonably have resulted in a catastrophic release) must be investigated.

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