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Risk Management
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.
Services Offered
Primatech works with clients to cover
the RMP requirements to:
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Develop and implement a
Management System
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Conduct a Hazard
Assessment
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Develop and implement a
Prevention Program
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Develop and implement an
Emergency Response Plan
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Submit a Risk Management
Plan
We also assist clients in preparing
updates to RMPs and risk management plans. These are required within
five years of their previous submission, for new processes, or whenever
a process becomes covered under the regulations, and when certain types
of process changes are made.
We develop a Management System by
working with our clients to assign responsibilities for the overall
program and individual program elements, and by defining 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. We follow guidelines similar to PSM for their development.
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.
Primatech has developed RMPs for a variety of
facilities. We provide extensive knowledge of technical developments in
RMP and expectations for compliance with the regulations.
Primatech offers the training courses
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