RISK MANAGEMENT
PREVENTION | PUBLIC RELATIONS | PLANNING | ASSET PROTECTION | COMPLIANCE
THE RPM
GOAL.
The goal of a Risk Management Plan (RMP) is to prevent serious chemical accidents that could cause harm to the public and the environment and to reduce the potential impact of accidental releases. The goal of All Phase Environmental, Inc. is to help you develop or revise your RMP, submit it to the USEPA and assist you with the public meeting where you will be required to disclose the contents of your RMP. Remember, not only will regulators see your RMP; the communities around your facility will see it also. Don’t take chances with your image, contact us now to insure you develop a good RMP and good community relations.
RPM REGULATIONS.
Section 112(r) of the amended Clean Air Act (CAA) of 1990 mandates the RMP regulations. This section complements and supports the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986. It incorporates the process Safety Management Standards (PSM) of the 1970 Occupational Safety and Health Administration (OSHA) as defined in 29 CFR 1910.119. The RMP rules are codified in 40 CFR Part 68.
WHO MUST SUBMIT AN RPM.
A facility is required to submit an RMP if it stores or uses a chemical in quantities greater than their threshold amounts as defined by the USEPA. The list includes toxics, reactive compounds, explosives, pyrotechnics, flammable liquids and gases. Retail facilities, companies operating under a specific list of SIC codes and facilities where the regulated substances are under active shipping papers are exempt from developing an RMP. An RMP is required for many warehouse facilities storing covered products. Chemical manufactures, bulk propane dealers, utilities and cold storage facilities are also covered by the RMP regulations.
RPM CONTENTS:
All Phase Environmental will assist you in putting your plan together and writing it in the USEPA’s required format of RMP Submit®. The following list includes some of the more prominent sections of your RMP.
1.
A description of the stationary source and regulated substances handled.
4.
An offsite consequence analysis evaluating potential release scenarios including worst-case and alternative scenarios.
7.
The RMP will be revised at least once every five (5) years or immediately if there are changes in corporate personnel or in the covered processes.
2.
The accidental release prevention and emergency response policies.
5.
A five (5) year accident history of accidental releases of regulated substances from the covered processes.
8.
Results of the public meeting where you disclosed the contents of your RMP and evidence of your efforts to bring the local community to this meeting.
3.
An emergency response program.
6.
An accidental release prevention program and process specific prevention steps.
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9.
An overall management system to supervise the implementation of the RMP program elements.
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