The U. S Environmental Protection Agency has issued a Risk Management Plan (RMP) Rule that requires any facility that uses extremely hazardous substances in quantities above a threshold amount must develop and submit an RMP for that facility. If the material is considered to be toxic, that threshold amount is specific for the substance. If the material in question is considered to be flammable, that threshold amount is 10,000 pounds. The primary intention of the RMP is to develop a chemical accident prevention program that identifies the potential effects of a chemical accident, what steps are being taken to prevent an accident, and what emergency response procedures will be taken in the event of an accident.
There are three levels of RMP facilities and corresponding required activities. The EPA RMP Rule simply refers to these three levels as Program 1, 2, and 3 facilities. The higher the level, the more comprehensive the program that is required to address the safety and incident prevention measures of the facility. The degree or level to which a facility and program must be developed is based on:
- If there has been an accidental release of the regulated substance with significant exposures within the past five years.
- If there are any off-site "public receptors", i.e. residences, businesses, schools, hospitals, office buildings, parks, etc., located within a toxic or flammable endpoint distance.
- If the facility must also comply with the OSHA Process Safety Management (PSM) Standard
- If the facility is "manned", i.e., the location is operated, maintained, or serviced by employees who visit the facility for periods of time that would be classified as longer than periodic. Personnel are stationed at the facility.
- The degree to which emergency response procedures have been developed between the source facility and the local response agencies.
Program 1 Facility - Indicates that toxic or flammable materials are on the location, but if an incident were to occur, there are no public receptors in close enough physical proximity to the facility to suffer any significant, adverse effects of that release. And in addition, no significant release has occurred at that facility within the past five years.
Program 2
Facility
- Either had a significant release within the past five years, or has the potential for a release, and if that release were to occur, there are public receptors within the distance to endpoint of that release that could potentially suffer the effects of that release. There are also no personnel who are routinely stationed on that facility throughout any given time period.
Program 3 Facility - One that is elevated to that level from a Program 2 because it is a "manned" facility and, for some reason, it must also comply with the OSHA PSM standard.
Typically, a Program 1 facility is one that is remotely located, and there are no "neighbors" in close proximity. So if an incident were to occur, the off-site impacts would be minimal. And as can be deduced, Program 2 and 3 facilities and their required RMPs are much more thorough programs and preventive measures, and contain pre-determined emergency response activities as well. As mentioned above, Program 3 plans must also comply with the OSHA PSM standard. This requires that the RMP contain sections that address the following required 13 OSHA PSM elements:
- Process Safety Information
- Process Hazard Analysis
- Operating Procedures
- Training
- Contractors
- Pre-Startup Safety Reviews
- Mechanical Integrity
- Hot Work Permit
- Management of Change
- Incident Investigation
- Employee Participation
- Emergency Planning and Response
- Compliance Audits
The Rule requires that an RMP be submitted and then updated/resubmitted every five years. It also requires that a Compliance Audit be performed of the plan at least every three years. Any deficiencies or gaps must be identified, corrective actions established and addressed in a timely fashion, responsible parties assigned to address those gaps, and those closures documented.
Our Brammer HSE Services division is currently managing RMPs for clients and can help you develop and submit your RMP, maintain an existing RMP, perform those required Compliance Audits of your RMP, identify any deficiencies in your current program and assist in the closure of those gaps, and help in the preparation of and participate in any agency inspections of your facilities at your request.
