EPA is required by Section 112(r) of the Clean Air Act Amendments to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances, which is commonly known as the Risk Management Program (RMP) rule. Facilities that manufacture, use, store, or otherwise handle more than a threshold quantity of a regulated substance in a process are required to comply with the RMP regulations, which are established in 40 CFR part 68. The RMP rule is built upon existing industry codes and standards and includes a List of Regulated Substances, including their synonyms and threshold quantities (in pounds) to help assess if a process is subject to the RMP rule. Core elements of the RMP rule include the following:
- Process safety information,
- Process hazard analysis (PHA),
- Operating procedures,
- Training,
- Mechanical integrity,
- Management of change,
- Pre-startup review,
- Incident investigation,
- Employee participation,
- Hot work permits,
- Contractors,
- Audits, and
- RMP*eSubmit.
RMP regulations require owners or operators of covered facilities to implement a risk management program and to submit a RMP Plan to EPA. RMP is established to reduce chemical risk at the local level, and RMP Plans provide valuable information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community when needed. RMP Plans are also available to the public, which fosters communication and awareness to improve accident prevention and emergency response practices at the local level. RMP plans are revised and resubmitted to EPA every five (5) years.
Each facility’s RMP should address three (3) primary areas:
- Hazard assessment that details the potential effects of an accidental release, an accident history of the last five (5) years, and an evaluation of worst-case and alternative accidental releases;
- Prevention program that includes safety precautions and maintenance, monitoring, and employee training measures; and
- Emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g fire department) should an accident occur.
EPA has classified RMP processes into three (3) Programs (i.e., Program Level 1, Program Level 2, and Program Level 3) to ensure that individual processes are subject to requirements that appropriately match their size and the risks they pose. As a result, different facilities may have different requirements depending on their processes. Based on their limited potential for serious offsite consequences, Program 1 facilities are not required to implement a prevention program, an emergency response program, or a management system; however, facilities with processes in Program 2 and Program 3 must address all of the RMP elements.
For questions about RMP requirements, contact Environmental Compliance & Safety, Inc. at:
- Phone: (662) 840 5945
- Website: https://envirocomp.net/contact/
