PSM Technical Services, Inc.

12114 West Waterford Avenue Greenfield, WI 53228
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EPA RMP Rule
Risk Management - Chemical Accidental Release Prevention

The U.S. Environmental Protection Agency (EPA) recently promulgated the Risk Management Program (RMP) rule for Chemical Accident Release Prevention. If a regulated chemical is present in a process at or above its threshold quantity, the rule requires the facility to develop and implement a risk management program to minimize the potential for and severity of chemical accidents. (The regulated toxic chemicals and flammable substances are listed on the reverse side with their respective threshold quantity.) More than 100,000 processes are expected to be affected by this rule.

RMP is a result of the Clean Air Act (CAA). CAA mandated that OSHA and EPA each develop chemical risk management rules. OSHA met that goal in 1992 with its Process Safety Management (PSM) standard. EPA has incorporated elements of the PSM standard into the RMP rule. The RMP rule has four main components:

Hazard Assessment: used to determine how complex and comprehensive a facility's chemical risk management program must be. This component includes analyses of worst-case and alternative release scenarios.
Prevention Program: includes safety information and a review of process hazards, as well as operating procedures, training and maintenance. The program must also specify guidelines for incident investigations and compliance audits.
Management Program: requires official documentation of the complete chemical risk management and prevention program implemented by a facility.
Emergency Response Plan: is a plan of action designed for the organizations that may respond to an accident. It details what steps should be taken, by whom, to ensure the safety of personnel at risk, and to minimize the impact of the accident.

Not all facilities utilizing regulated substances pose the same risk. For this reason, the RMP has three program categories with varying levels of complexity. Facilities must determine which program applies to an affected process prior to formulating a risk management strategy.

Program 1 A minimal program for facilities with no history of off-site accidents and no public receptors in the area of risk.
Program 2 An expanded program for facilities that do not fit into Program 1 or Program 3.
Program 3 A comprehensive program aimed at facilities subject to the OSHA PSM standard or SIC codes 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, or 2911.

Facilities were required to submit a Risk Management Plan prior to June 21, 1999, including:

Executive summary
Registration
Off-site consequence analysis
Five-year accident history
Emergency response plan
Prevention program summary information
Certification

PSM Technical Services, Inc. can help you develop and implement the requirements of this regulation, and assist your staff in achieving more than just compliance.