Risk Management Plan (RMP)

EPA requirements for extremely hazardous chemicals

Envirosure regularly assists in the development of OSHA Process Safety Management (PSM) and EPA Risk Management Plans (RMP)

OSHA’s PSM program is designed to protect the worker in facilities that use hazardous chemicals. EPA’s RMP program is designed to protect the environment and the surrounding community from hazardous chemicals.

OSHA and EPA have defined and listed hazardous and extremely hazardous chemicals that, in the event of accidental release, could cause death, injury or serious health effects. These lists contain threshold values for each chemical with specific requirements dependant upon amount of chemical on site.

Envirosure’s Chemical Inventory Program (HMIS) provides the basis for generating PSM and RMP plans for any given facility.

RMP_01As an example of PSM/RMP development, let’s discuss a facility which has an ammonia refrigeration system. Ammonia is listed as an “extremely hazardous chemical” with a reportable threshold (RT) of 500 pounds. Businesses having over 500 pounds of ammonia on site are required to report their annual chemical inventories to Local Emergency Planning Committees (LEPC) and the State Emergency Response Commission (SERC) by submitting annual chemical inventory reports (Tier I and Tier II Forms), and report the accidental release of over 100 pounds to SERC and LEPC.

If a refrigeration system contains more than 10,000 pounds of ammonia, PSM and RMP plans must be in place. Typical RMP for a plant with an ammonia refrigeration system would encompass: Safety information; Hazard review; Operating procedures; Training; Maintenance procedures; Compliance audits; Incident investigation; Management system; Hazard assessment; and a Prevention program (OSHA’s PSM).

A five year accident history is a mandatory part of the hazard assessment, and it must be included in the plan.

It should be noted that regardless of the amount or type of chemicals in any facility, EPA Clean Air Act Section 112(r) contains a General Duty Clause (GDC) which in part states “…the owners and operators of stationary sources producing, processing, handling, or storing such substances have a general duty… to identify hazards which may result from such releases using appropriate hazard assessment techniques to design and maintain a safe facility… “

OSHA / EPA compliance is a full time job requiring that EHS professionals provide the necessary planning, programs, implementation, management, training, enforcement, reports, documentation. and follow-through to maintain your firm’s position as being “in compliance”. With expertise and technology, Envirosure has systemized procedures to cost effectively accommodate compliance requirements, allowing you to concentrate on your core business.

We welcome the opportunity to discuss your EHS compliance requirements.  Give us a call today at 480-784-4621. 

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