Emergency planners around the country are re-assessing their ability to cope with a major disaster. News media have gone beyond wind and water damage to spotlight chemical release effects and major chemical disaster risk. A September 18th Philadelphia Inquirer article reprised the overlapping “worst-case” impact areas from the region’s refineries and chemical users not seen for several years since the EPA Risk Management Programs rule (40 CFR Part 68) came into effect in 1999.
This is a good time for all organizations to re-assess their planning for disaster prevention, response and recovery. Some questions you might ask within your organization are: Is our Emergency Response Plan based on the range of catastrophic release hazards that can be caused by natural events, intentional acts and accidents?
Has our chemical release prevention program been kept current and does it consider the full range of accidental and intentional acts?
This is a good time to capitalize on the heightened awareness of facility and management staff and update your programs and plans and conduct training and exercises.
When Am I Subject to RMP General Duty? If you “dodged the RMP bullet” by keeping inventories under the Threshold Quantities – the General Duty Clause (Section 112(r)(1) of the Clean Air Act) makes any extremely hazardous substance, not limited to the RMP or EPCRA lists or thresholds, subject to RMP General Duty. Any chemical that can cause injury or property damage through vapor exposure, fire or explosion is covered. It requires owners and operators to:
Identify accidental release hazards of extremely hazardous substances using hazard assessment
Design and maintain a safe facility
Minimize the off-site consequences of accidental releases that do occur
EPA 550-B00-002, May 2000, outlines a General Duty program that is quite comparable to a RMP “Prevention Program 2”, including performing accidental release modeling! For more information on RMP General Duty, let us know if you would like a paper explaining General Duty in greater detail.
Prevention Planner How do you keep current on recurring obligations for EPA RMP regulated facilities or those covered by the “General Duty Clause”? Using a “tickler” or tracking system will ensure that you remain current through any facility changes, staff changes, AND for the following key recurring obligations:
2005 Rule Changes on When RMP is Re-Submitted 2005 RMP rule changes added the top 2 RMP re-submittal requirements to the previous list. These changes require you to stay on your toes!
Environmental and Engineering Solutions, Inc. can assist you with chemical risk management and with your obligations under EPA’s Risk Management Programs rule. Contact Tom Petersen of EES at (215) 704-1506 or tom@eesolutions.net for further information or to set up an appointment.
(Copyright 2005 by Environmental and Engineering Solutions, Inc.)
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