Risk Management Program (RMP) Support

Companies that handle certain highly hazardous chemicals in excess of threshold quantities must comply with EPA’s Risk Management Program (RMP) rule, 40 CFR Part 68. EPA’s RMP rule embraces OSHA’s PSM standard but applies it to protection of the public and the environment rather than employees as is the case with OSHA. However, the RMP rule goes beyond PSM in its requirements.

For example, it requires the determination of impact distances for a worst-case accident and at least one alternative release scenario. These additional aspects of the RMP regulation require technical expertise beyond that required for PSM. As with PSM, the RMP regulation is performance-based and compliance with it is quite different from specification-based regulations that spell out requirements. Decisions must be made by companies on how to meet the regulatory requirements and what levels of performance are appropriate. As technical improvements are made, EPA’s expectations for performance increase. Companies must stay abreast of these developments and adjust their programs accordingly. For these reasons, many companies find it is more cost effective to seek outside expertise in developing and maintaining their RMPs.

Details

Services Offered

• Development of Risk Management Programs.

   

• Full Risk Management Program development can include all levels of implementation assistance.

   

• Preparation of updates to Risk Management Plans.

Other Information

The Management System requires the assignment of responsibilities for the overall program and individual program elements and the definition of lines of authority. The Hazard Assessment involves an Offsite Consequence Analysis (OCA) and the compilation of a five-year accident history for the process. The OCA considers worst-case and alternative release scenarios so that impacts on the population and the environment can be determined.
The Prevention Program is EPA’s equivalent of OSHA’s PSM Program and the Emergency Response Plan is similar to the Emergency Planning and Response element of OSHA’s PSM standard. The Risk Management Plan is used to notify EPA that a facility is covered under the regulations and provides summary information about the RMP. It must be certified by signature of a company representative.