Risk Management Program (RMP) Support

The RMP rule goes beyond PSM in its requirements.

The Prevention Program within the Risk Management Program rule is EPA’s equivalent of OSHA’s PSM Program while 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 a company representative and submitted along with periodic updates.

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 customized, site specific Risk Management Programs
• Preparation of updates to Risk Management Plans
• Electronic submittal of RM Plans and updates

Updates are required within five years of the submission of the previous Risk Management Plan, for new processes, whenever a process becomes covered under the regulations, and when certain types of process changes are made. We help develop your submittals and ensure any RMP updates / re-submittals meet EPA’s latest requirements.

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.