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Description

Companies that handle certain highly hazardous chemicals in excess of threshold quantities must comply with EPA's Risk Management Program (RMP) rule, 40 CFR Part 68. EPA's RMP rule embraces OSHA's PSM standard but applies it to protection of the public and the environment rather than employees as is the case with OSHA. However, the RMP rule goes beyond PSM in its requirements. For example, it requires the determination of impact distances for a worst-case accident and at least one alternative release scenario. These additional aspects of the RMP regulation require technical expertise beyond that required for PSM.

As with PSM, the RMP regulation is performance-based and compliance with it is quite different from specification-based regulations that spell out requirements. Decisions must be made by companies on how to meet the regulatory requirements and what levels of performance are appropriate. As technical improvements are made, EPA's expectations for performance increase. Companies must stay abreast of these developments and adjust their programs accordingly. For these reasons, many companies find it is more cost effective to seek outside expertise in developing and maintaining their RMPs.

RMP Requirements

  • Development and implementation of a Management System
  • Conduct of a Hazard Assessment
  • Development and implementation of a Prevention Program
  • Development and implementation an Emergency Response Plan
  • Submission of a Risk Management Plan

The Management System requires the assignment of responsibilities for the overall program and individual program elements, and the definition of lines of authority. The Hazard Assessment involves an Offsite Consequence Analysis (OCA) and the compilation of a five-year accident history for the process. The OCA considers worst-case and alternative release scenarios so that impacts on the population and the environment can be determined.

The Prevention Program is EPA's equivalent of OSHA's PSM Program and the Emergency Response Plan is similar to the Emergency Planning and Response element of OSHA's PSM standard. The Risk Management Plan is used to notify EPA that a facility is covered under the regulations and provides summary information about the RMP. It must be certified by signature of a company representative.

Why Develop a Risk Management Program?

Risk management programs are required by the US EPA and similar programs are required in other parts of the world. They protect the public and the environment. Such programs are good engineering practice for the process industries.

Why Primatech?

Primatech has developed many Risk Management Programs and we have prepared RMP submissions, updates and re-submissions for numerous facilities. We provide extensive knowledge of technical developments in RMP and expectations for compliance with the regulations.

EPA has changed the requirements for RMP updates and re-submittals. New requirements include, among other things:

  • Added RMP data elements.
  • Modifications to the re-submission schedule for certain affected sources / companies.
  • Revisions to the re-submission format.

Primatech can help you take the guess-work out of trying to meet these new requirements.

Services Offered

  • Development of Risk Management Programs.

    Primatech develops full Risk Management Programs. We provide program documentation and usually assist with its implementation.

  • Preparation of updates to Risk Management Plans.

    Updates are required within five years of the submission of the previous Risk Management Plan, for new processes, whenever a process becomes covered under the regulations, and when certain types of process changes are made. Primatech helps to ensure your RMP update and re-submittal to the EPA meets EPA's current requirements.
 

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