Risk Management Plan

RMP In June 1996 USEPA published the final CAA Section 112(r) rules governing the federally mandated risk management plan (RMP). The promulgation of the RMP rules were prompted, in part, due to the EPA's assertion that historical releases occurred as a result of an ignorance of process hazards, and is intended to prevent the accidental releases of regulated substances. The regulated substances of concern included in a list of 77 toxic substances, 63 flammable substances.
In general, facilities with threshold amounts of the regulated substances within their processes are subject to this rule. Threshold quantities are 10,000 lbs. for flammables and range from 500 lbs. to 20,000 lbs. for toxic chemicals. It is important to note that the applicability thresholds and regulations apply to individual processes rather than the entire facility; as such, each process must be reviewed individually to determine the applicability of this regulation. Facilities may wish to consider implementing process changes, such as a reduction of on-site storage of a particular substance, to avoid the applicability of these rules.

The final RMP rule establishes three levels of requirements in an effort to reduce the level of regulatory burden on low-risk facilities. The applicability review conducted on each process will determine the program level to which the process is subject. Program Level 1 has the fewest requirements while Program Levels 2 and 3 require more work because of increased risk to a facility's surrounding communities. The basic provisions of the RMP regulations require facilities to identify and control on-site hazards through a series of detailed steps, and to inform the public of the actions that they are taking to prevent and mitigate the potential off-site effects of these hazards. Depending on the applicable 'Program Level,' some of the tasks that facilities may be required to undertake include determining a worst-case release scenario as well as a more plausible "alternative' release scenario, perform computer-aided modeling to determine off-site impacts, develop a prevention program and an emergency response program with appropriate employee training. In addition, disseminating information to the public may potentially pose the greatest challenge to facilities. It is important to provide the release impact information in a manner which will emphasize preventative measures rather than the risk potential. Facilities are required to comply with the provisions of this federal regulation by June 21, 1999.

The regulations governing the federal risk management programs can be complex, depending on the type of facility and processes operated. Envirologic's trained professionals can assist you to address these rules. Should you require additional information, would like to receive a list of the regulated substances, or wish to further discuss the RMP rules, please do not hesitate to contact our office at 616-342-1100.

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