EPA's Risk Management Planning Rules - Summarized with Guides and Regulations
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EPA's Risk Management Planning Rules - Summarized with Guides and Regulations
This page is designed to be a one-stop shopping for RMP - Risk Management Planning for facilities.
Overview
Preparing a Risk Management Plan
Please consult the following sources, in addition to the RMP rule, before preparing your plan:
- Risk Management Program Guidance - EPA provides several guidance documents to help facilities understand and comply with the RMP rule.
- 40 CFR 68.130 (Full Text) - A full list of chemicals regulated under the RMP rules.
- Title III Consolidated List of Lists - October 2006 Version - The Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-Know Act and Section 112(r) of the Clean Air Act helps facilities determine whether they will be subject to the Chemical Accident Prevention Provisions.
EPA developed a suite of software applications to allow facilities to prepare and submit their RMPs in electronic format and to assist EPA in processing and managing the RMPs. The applications include:
- RMP*Submit 2004 - EPA developed free software for facilities to use in submitting their Risk Management Plans.
- RMP Comp - This electronic tool performs the off-site consequence analysis required under the Risk Management Program
Submitting a Risk Management Plan
After you have prepared your plan using RMP*Submit 2004, please review the important reminders and then submit your plan. As necessary, you may also re-submit, correct, or withdraw an RMP.
Accessing RMP Information
RMP information may be accessed via the Federal Reading Rooms:
- Federal Reading Rooms are open and available to the public to review RMP information.
For More Information
- Superfund, TRI, EPCRA, RMP & Oil Information Center - The Information Center can also answer questions related to Clean Air Act section 112(r) and RMP reporting requirements.
- RMP Reporting Center - The Reporting Center can answer questions about software or installation problems.
The eligibility criteria and requirements for the three different program levels are as follow.
Note: try our free interactive web guide to quickly determine which program applies to your situation .
PROGRAM ELIGIBILITY CRITERIA
No public receptors in worst-case circle
Emergency response coordinated with local responders
Process not eligible for program 1 or 3
Process is SIC code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, or 2911
Hazard Assessment
Worst-case analysis
5-yr accident history
Certify no additional steps needed
Hazard Assessment
Worst-case analysis
Alternative releases
5-yr accident history
Management Program
Document management system
Prevention Program
Safety information
Hazard review
Operating procedures
Training
Maintenance
Incident investigation
Compliance audit
Emergency response program
Develop plan & program
Hazard Assessment
Worst-case analysis
Alternative releases
5-yr accident history
Management Program
Document management system
Prevention Program
Process safety information
Process hazard analysis
Operating procedures
Training
Mechanical integrity
Incident investigation
Compliance audit
Management of change
Pre-startup safety review
Contractors
Employee participation
Hot work permits
Emergency Response Program
Develop plan & program
The EPA rule also requires regulated facilities to develop a Risk Management Plan (RMP). The RMP will include a description of the hazard assessment, prevention program, and the emergency response program. Facilities will submit the RMP to governmental agencies, the state emergency response commission, the local emergency planning committees, and as needed the RMP would be communicated to the public.
The final rule defines the worst-case release as the release of the largest quantity of a regulated substance from a vessel or process line failure, including administrative controls and passive mitigation that limit the total quantity involved or release rate. For gases, the worst-case release scenario assumes the quantity is released in 10 minutes. For liquids, the scenario assumes an instantaneous spill and that the release rate to the air is the volatilization rate from a pool 1 cm deep unless passive mitigation systems contain the substance in a smaller area. For flammables, the scenario assumes an instantaneous release and a vapor cloud explosion using a 10 percent yield factor. For alternative scenarios (note: EPA is using the term alternative scenario as compared to the term more-likely scenario used earlier in the proposed rule), facilities may take credit for both passive and active mitigation systems.
Appendix A of the final rule lists endpoints for toxic substances to be used in worst-case and alternative scenario assessment. The toxic endpoints are based on ERPG-2 or level of concern data compiled by EPA. The flammable endpoints represent vapor cloud explosion distances based on overpressure of 1 psi or radiant heat distances based on exposure to 5 kW/m 2 for 40 seconds.
The promulgation of the final rule follows some recent actions by EPA to amend the final list rule promulgated earlier by EPA on January 31, 1994. These recent actions include the following proposed amendments to the list rule:
- Exemption of crude oil prior to initial processing and gasoline,
- The risk management program rule does not apply to sources in the outer continental shelf,
- Entire weight of the mixture containing a flammable substance shall be treated as a regulated substance unless experimental measurements can demonstrate that the mixture does not meet NFPA 4 criteria, and
- Exemption of explosives (as defined under DOT Class 1, Division 1.1 - 49 CFR 172.101) from coverage by the rule.
The EPA has proposed a stay of effectiveness of the risk management program rule requirements for those facilities impacted by the proposed amendments to the list rule.
This summary of the risk management program rule summarizes important aspects of 40 CFR 68.
- Accidental Release Prevention Requirements: Risk Management Programs Under Clean Air Act Section 112(r)(7).
- List of Regulated Substances and Thresholds for Accidental Release Prevention; Requirements Petitions Under Section 112(r) of the Clean Air Act as Amendf.
- EPA/CEPPO Clean Air Act - Section 112(r) - Frequently Asked Questions (FAQs).
- Risk Management Plan Data Element Instructions.
- MOU OSHA and EPA Accident Investigations.
- The latest news about accidents and list of accidents
- MODEL RISK MANAGEMENT PROGRAM AND PLAN FOR AMMONIA REFRIGERATION, MAY 1996.
Risk Management Planning Tools and Computer Software
RMP*Comp
RMP*Comp is an electronic tool used to perform the off-site consequence analysis required under the Risk Management Program rule published by the Environmental Protection Agency on July 20, 1996, which implements Section 112(r) of the Clean Air Act. Previously, EPA has referred to this tool as RMP Calculator or RMP Assistant. RMP*Comp makes the same calculations that you can make manually by following the procedures described in EPA's guidance document, RMP Offsite Consequence Analysis Guidance (April 1999) .
For more information, please see RMP*Comp .
RMP*Submit 2004
RMP*Submit 2004 is the free, official EPA, personal computer software for facilities to use in submitting Risk Management Plans (RMPs) required under the Risk Management Program. Use RMP*Submit 2004 to prepare your initial RMP and any corrections or resubmissions.
For more information, please see RMP*Submit 2004 .
Tier2 Submit 2006
EPA developed Tier2 Submit 2006 to help facilities prepare an electronic chemical inventory report. Many states accept Tier2 Submit.
For more information, please see Tier II Chemical Inventory Reports / Tier2 Submit .
Title III Consolidated List of Lists - October 2006 Version
The Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 112(r) of the Clean Air Act (also known as the List of Lists) was prepared to help firms handling chemicals determine whether they need to submit reports under sections 302, 304, or 313 of EPCRA and, for a specific chemical, what reports may need to be submitted. It will also help firms determine whether they will be subject to accident prevention regulations under CAA section 112(r). These lists should be used as a reference tool, not as a definitive source of compliance information. Compliance information for EPCRA is published in the Code of Federal Regulations (CFR), 40 CFR Parts 302, 355, and 372. Compliance information for CAA section 112(r) is published in 40 CFR Part 68. The List of Lists is available several formats.
- Searchable database - Title III Consolidated List of Lists
- Adobe PDF - Title III Consolidated List of Lists - October 2006 (105 pp, 5.5MB, About PDF )
- Microsoft Excel - Title III Consolidated List of Lists - October 2006 (289K, XLS)
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