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Risk Management Plan (RMP) Guides and publications - free from EHSO

Risk Management Planning (RMP)
Regs, Guides, Publications & Fact Sheets
presented by EHSO

Contents

• General Information Overview Submitting a Risk Management Plan Re-submitting, Correcting, or Withdrawing an RMP

• Laws and Regulations Guidance for facilities in RMP-authorized states (such as the State of Georgia)

Checklists EPA RMP Checklist

Guidance

Other Links Non-EPA Sites

Description:

Section 112(r) of the Clean Air Act (CAA) requires covered facilities to develop risk management programs to prevent accidental releases of dangerous chemicals. Facilities are required to submit risk management plans (RMPs) to a central location by June 1999. The RMPs will be electronically available to State and local governments and citizens to help them understand local chemical hazards and take steps to prevent accidents. Obviously, you want to take great care that they are complete and accurate, but do not exaggerate nor understate the risks! This page provides access to information on the legislation, and supporting regulation, guidance, fact sheets, and systems related to this section of the law.

For an overview of Chemical Accident Prevention and Risk Management Planning, please see the EPA fact sheets available here and training modules. Copies of documents may be obtained in hard copy from EHSO (Benivia, LLC) at

For assistance in identifying appropriate information and information sources and in answering factual questions about RMPs and implementation of CAA 112(r), contact EHSO at 770-645-0788 or the RCRA/UST/Superfund/EPCRA Hotline. Regional and EPA Headquarters 112(r) Contacts are available to answer the more interpretive policy questions and handle issues related to RMP implementation. Suggestions or comments about what is on this web page may be sent through the EHSO feedback form. The EHSO feedback form may also be used to pose questions of policy interpretation, too, although these will be routed through our Question and Answer process and answers will only be posted on the Q and A database.

Information related to CAA 112(r) will be posted on this page as it becomes available.

• The Accident Prevention Subcommittee page focuses on the scientific and technical aspects related to Section 112(r) of the Clean Air Act as Amended in 1990. In November 1998, after much debate, a letter describing EPA's decision not to post the OCA data on the Internet was sent to this sub-committee. The Risk Management Program Implementation Workgroup page focuses on the facilitating the implementation of EPA's Risk Management Program Rule. The Electronic Submission Workgroup page focuses on the task of determining how electronic submission of "risk management plans" (RMPs) can be accomplished and how the public can best access and utilize the data. The Workgroup completed its work in June, 1997.

Checklists

New RMP Factsheet: A Checklist for Resubmitting Your Risk Managment Plan (RMP) for Chemical Accident Prevention

In 1996, EPA established a list of extremely hazardous substances and issued regulations for the prevention and mitigation of accidental releases of those substances under section 112(r) of the Clean Air Act. Facilities covered by the regulations are required to implement a risk management program and submit a description of the program (called a risk management plan, or RMP) to EPA.

RMPs must be updated at least once every five years. The majority of facilities submitted their initial RMP's by the original June 21, 1999 deadline and have not resubmitted their RMPs since. This means that most RMP's must be fully updated and resubmitted by June 21, 2004.

This PDF guide should prove very useful: A Checklist for Resubmitting Your Risk Management Plan (RMP) For Chemical Accident Prevention

This factsheet (an MS Word document) provides another checklist for preparing a 5-year update. It is important that owners and operators responsible for RMP implementation review this information and take appropriate steps to update their RMPs.

Risk Management Plan (RMP) Rule

Guidance Documents

• General Risk Management Plan Guidance
• Propane Storage Facilities Risk Management Plan Guidance
• Wastewater Treatment Plants Risk Management Plan Guidance
• Warehouses Risk Management Plan Guidance
• Chemical Distributors Risk Management Plan Guidance
• Offsite Consequence Analysis Risk Management Plan Guidance
• Technical Background Document for Offsite Consequence Analysis for Anhydrous Aqueous Ammonia, Chlorine, and Sulfur Dioxide
• myRMP Suite of Retail Agriculture Guidance Materials
  
• Guidance for Implementation of the General Duty Clause Clean Air Act Section 112(r) (PDF) (55 pp, 367K)
• RMPs Are on the Way! - How LEPCs and other Local Agencies Can Include Information from Risk Management Plans in Their Ongoing Work (PDF) (62 pp, 1.1MB)
  Issued: November 1999
• Guidance for Auditing Risk Management Plans/Programs under the Clean Air Act Section 112(r) (PDF) (94 pp, 855K)
  Issued: August 1999
• Risk Management Programs under Clean Air Act Section 112(r): Guidance for Implementing Agencies (PDF) (58 pp, 144K)
  Issued: February 1998
• Risk Management Program Guidances Errata Sheet (PDF) (8 pp, 19K)
• Ammonia Refrigeration Risk Management Plan Guidance

Related Policies

• Security Notice To Federal, State and Local Officials Receiving Access to the Risk Management Program's Off-site Consequence Analysis Information (PDF) (8 pp, 37K)
  Issued: October 2004
• Strategy for Coordinated EPA/Occupational Safety and Health Administration (OSHA) Implementation of the Chemical Accident Prevention Requirements of the Clean Air Act Amendments of 1990 (PDF) (2 pp, 15K)
  Issued: August 1998
• Memorandum of Understanding between EPA and CSB on Chemical Incidents (PDF) (10 pp, 22K)
  Issued: March 1999

Fact Sheets

• Public Distribution of Off-Site Consequence Analysis Information (PDF) (3 pp, 406K)
  Issued: August 2000
  Describes the final regulations governing access to and dissemination of restricted forms of information about the potential off-site consequences of accidental chemical releases.
• FBI/EPA fact sheet Chemical Safety Information, Site Security and Fuels Regulatory Relief Act: Public Meetings and Other Notification (PDF) (4 pp, 89K)
  Issued: October 1999
  
  Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (PDF) (2 pp, 78K)
  Issued: August 1999
  EPA has prepared a fact sheet that describes the law's requirements.
• US EPA Assessment of the Incentives Created by Public Disclosure of Off-Site Consequence Analysis Information for Reduction in the Risk of Accidental Releases (PDF) (149 pp, 1MB)
  Issued: April 18, 2000
• Changes to the Chemical Accident Prevention Rule (Risk Management Program) in 2004 (PDF) (3 pp, 37K)
  Issued: March 2004
• The General Duty Clause Fact Sheet (PDF) (2 pp, 51K)
  Issued: June 1999
• Owners, Operators of Stationary Sources Must Comply with Clean Air Act's "General Duty" Clause (PDF) (2 pp, 47K)
  Issued: August 1998
• Changes to the Risk Management Program Rule (PDF) (2 pp, 134K)
  Issued: December 1998
• Risk Management Planning: Accidental Release Prevention; Final Rule: Clean Air Act section 112(r) (13K, TXT)
  Issued: May 1996
• Chemical Accident Prevention and the Clean Air Act Amendments of 1990 (19K, TXT) Issued: May 1996
• Fact Sheet: Risk Management Plan (RMP) Audit Program (PDF) (2 pp, 71K)
• Small Business and the Risk Management Program (PDF) (4 pp, 229K)
  Issued: April 1998
• The General Duty Clause Fact Sheet (PDF) (2 pp, 51K)
  Issued: June 1999
• Funding Sources for Implementing the Risk Management Program Fact Sheet, May 1998

• Originally appeared in the December 1997 report, State Strategies and Considerations for Implementing the Chemical Accidental Release Prevention Program, which was prepared by the National Governors' Association Center for Best Practices under a cooperative agreement with EPA.

• Chemical Emergency Preparedness and Prevention in Indian Country (PDF) (5 pp, 56K)
  Issued: August 2002
• Accidental Release Information Program (ARIP) Fact Sheet (PDF) (2 pp, 56K)
  Issued: November 1994

FAQs - Frequent Questions

• Risk Management Program Amendments Rule FAQs
  Issued: April 2004
  These questions and answers concern the final amendments to the submission schedule and data elements. This rule was published on April 9, 2004.
• Clean Air Act 112(r) Frequently Asked Questions
  Revised: February 2006
  These questions and answers regarding the Risk Management Program Rule under the Clean Air Act Section 112(r) have been approved for release.
• Chemical Safety Information, Site Security, and Fuels Regulatory Relief Act (PL 106_40) Frequently Asked Questions and Answers
  Issued: June 2000
  Find out more about public meetings, certification, and notification requirements of this new law. This applies to facilities that report Risk Management Plans under the Clean Air Act Section 112(r).
• OSHA's Standard Interpretations and Compliance Letters
  A text-searchable web site for of interpretations of the OSHA Standards, by USDOL OSHA - Directorate of Compliance Programs. Since OSHA's PSM program is so closely related to EPA's RMP program, a link is being made to this OSHA page which provides search capabilities as well as numeric and chronological listing of frequent questions.

Laws Defining EPA's Emergency Management Program

Law	Overview	Full Text
Clean Air Act (CAA)	Overview	42 U.S.C. 7401-7671
Clean Water Act (CWA)	Overview	33 U.S.C. 26
Oil Pollution Act (OPA)	Overview	33 U.S.C. 40
Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA)	Overview	42 U.S.C. 103
Superfund Amendments & Reauthorization Act (SARA)	Overview	42 U.S.C. 103
Emergency Planning & Community Right-to-Know (EPCRA)	Overview	42 U.S.C. 116
Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (CSISSFRRA)	Overview	42 U.S.C. 7412(r)
Hazardous Materials Transportation Act (HMTA)	Overview	49 U.S.C. 5101-5127 Regulations Implementing EPA's Emergency Management Program Regulation Overview Full Text Related FR Notices Chemical Accident Prevention Provisions Overview 40 CFR 68 FR Notices Discharge of Oil Overview 40 CFR 110 FR Notices Oil Pollution Prevention Overview 40 CFR 112 FR Notices National Oil and Hazardous Substances Pollution Contingency Plan Overview 40 CFR 300 FR Notices Designation, Reportable Quantities, and Notification Overview 40 CFR 302 FR Notices Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases Overview 40 CFR 310 FR Notices Emergency Planning and Notification Overview 40 CFR 355 FR Notices Hazardous Chemical Reporting: Community Right-to-Know Overview 40 CFR 370 FR Notices Criteria for State, Local and Regional Oil Removal Contingency Plans Overview 40 CFR 109 FR Notices Each regulation is referenced by its location in the Code of Federal Regulations (CFR). For example, "40 CFR 300" means that the regulation is in Volume 40, Part 300 of the CFR. Relevant Federal Register Notices Chemical Accident Prevention Provisions; 40 CFR 68 Discharge of Oil; 40 CFR 110 Oil Pollution Prevention; 40 CFR 112 National Oil and Hazardous Substances Pollution Contingency Plan; 40 CFR 300 Designation, Reportable Quantities, and Notification; 40 CFR 302 Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases; 40 CFR 310 Emergency Planning and Notification; 40 CFR 355 Hazardous Chemical Reporting: Community Right-to-Know; 40 CFR 370 Criteria for State, Local and Regional Oil Removal Contingency Plans; 40 CFR 109 Chemical Accident Prevention Provisions; 40 CFR 68 April 9, 2004: Accidental Release Prevention Requirements: Risk Management Program Requirements Under Clean Air Act Section 112(r)(7); Amendments to the Submission Schedule and Data Requirements; Final Rule. 69 FR 18819 (PDF) August 4, 2000: Accidental Release Prevention Requirements; Risk Management Programs Under the Clean Air Act Section 112(r)(7); Distribution of Off-Site Consequence Analysis Information; Final Rule. 65 FR 48107 (PDF) March 13, 2000: Amendments to the List of Regulated Substances and Thresholds for Accidental Release Prevention; Flammable Substances Used as Fuel or Held for Sale as Fuel at Retail Facilities; Final Rule. 65 FR 13243 (PDF) February 22, 2000: Delegation of Authority to Conduct Assessments and Promulgate Regulations On Public Access to Off-Site Consequence Analysis Information (January 27, 2000 Memorandum). 65 FR 8631 (PDF) January 6, 1999: Accidental Release Prevention Requirements; Risk Management Programs Under Clean Air Act Section 112(r)(7); Amendments; Final Rule. 64 FR 963 (PDF) January 6, 1998: List of Regulated Substances and Thresholds for Accidental Release Prevention; Final Rule. 63 FR 639 (PDF) August 25, 1997: List of Regulated Substances and Thresholds for Accidental Release Prevention; Final Rule. 62 FR 45129 (PDF) August 25, 1997: Accidental Release Prevention Requirements; Interpretations; Final Rule. 62 FR 45133 (PDF) June 20, 1996: Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Section 112(r)(7); List of Regulated Substances and Thresholds for Accidental Release Prevention, Stay of Effectiveness; and Accidental Release Prevention Requirements: Risk Management Programs Under Section 112(r)(7) of the Clean Air Act as Amended, Guidelines; Final Rules and Notice. 61 FR 31667 (PDF) Integrated Contingency Plan Guidance (One Plan) (Note: The official version of the One Plan Guidance was published in the Federal Register on June 5, 1996, and the official version in PDF format below contains the complete document as published. However, a correction was published in the Federal Register since several lines from table "DOT/RSPA FRP (49 CFR 194)" were omitted in the original published version. The text for the FR correction notice is also included below. The complete corrected version is available in WordPerfect format below.) The National Response Team's Integrated Contingency Plan Guidance (One Plan) (Corrected Version) (64 pp, 266K, WPD) The National Response Team's Integrated Contingency Plan Guidance (One Plan) (PDF) (24 pp, 830K) Issued: June 1996 National Response Team's Integrated Contingency Plan (One Plan) Guidance Fact Sheet (PDF) (2 pp, 189K) Issued: April 1998 Correction Notice for "The National Response Team's Integrated Contingency Plan Guidance (One Plan) (published June 19, 1996)" NRT-1: Hazardous Materials Planning Guide (2001 Update) (PDF) (118 pp, 765K) This update of the 1987 Hazardous Materials Emergency Planning Guide (NRT-1, "Orange Book") contains updated references to guidance on developing state and local emergency response plans. Brief references to recent legislation have been incorporated to encourage plan integration and coordination. This updated version of NRT-1 includes new guidance on integrating local emergency response plans prepared and updated by Local Emergency Planning Committees (LEPCs) with the planning requirements contained in recent legislation. NRT-2: Developing a Hazardous Materials Exercise Program - A Handbook for State and Local Officials Top of page Related Non-EPA Sites Improving Risk Communication, National Academy Press, Washington, D.C., 1989 "Safety Street" and other materials on the Kanawha Valley Demonstration Program, Chemical Manufacturers Association, Arlington, VA Community Awareness and Emergency Response Code of Management Practices and various Guidance, Chemical Manufacturers Association, Arlington, VA Communicating Risks to the Public, R. Kasperson and P. Stallen, eds., Kluwer Publishing Co., 1991 "Challenges in Risk and Safety Communication with the Public," S. Maher, Risk Management Professionals, Mission Viejo, CA, April 1996 Primer on Health Risk Communication Principles and Practices, Agency for Toxic Substances and Disease Registry Risk Communication about Chemicals in Your Community: A Manual for Local Officials, US Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA Hotline Risk Communication about Chemicals in Your Community: Facilitator's Manual and Guide, US Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA Hotline Chemicals, the Press, and the Public: A Journalist's Guide to Reporting on Chemicals in the Community, US Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA Hotline Chemical Safety and Hazard Investigation Board (CSB) CSB was authorized on November 15, 1990 with the enactment of the amendments to the Clean Air Act (42 USC 7412). Modeled after the National Transportation Board (NTSB), CSB has been directed by Congress to conduct investigations and report on findings regarding the causes of chemical accidents. Those findings will be used to recommend actions to improve the safety of operations involved in the production, transportation, and industrial handling, use and disposal of chemicals. Chlorine Institute's page on the Risk Management Program Rule Includes a brochure, flowchart, and information about ordering the Generic Risk Management Plan For Chlorine Packaging Plants and Sodium Hypochlorite Production Facilities. Hot Topics at Safety Online Another source for downloading the CAA 112(r) rule, data elements, and off-site consequence analysis. Idaho site A site devoted to the one-plan concept for farms. Michigan's Air Quality Division page on CAA 112(r) A page devoted to CAA 112(r) providing background, frequently asked questions and answers, and a discussion of how Title V sources must report that they are in compliance. Risk Assessment and Risk Management in Regulatory Decision-Making A document issued by the Presidential/ Congressional Commission on Risk Assessment in 1997 and available from the Commission's web site on Riskworld . Published in 2 long volumes, but you can view the table of contents for each volume in HTML and go to relevant sections from there. Available at no cost. For a hard copy, contact the Commission's office at (202) 233-9537.