New Jersey Technical Assistance Program for Industrial Pollution Prevention			New Jersey Technical Assistance Program for Industrial Pollution Prevention
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Home Write Us About NJTAP Success Stories P2 Information Regulatory Staff Bios EnviroDaemon Search Engine New Jersey EnviroDatabases Links WANTED!! Reference NJIT Home Page			Risk Management Planning: Accidental Release Prevention Final Rule: Clean Air Act Section 112(r) The risk management planning requirements of CAA section 112 (r) complement and support the Emergency Planning and Community Right-to-Know Act of 1986. EPCRA improves the ability of communities to prepare for and respond to chemical accidents. Under EPCRA, communities must develop emergency response plans, based on information that facilities must provide on the hazardous chemicals they handle. The CAA's section 112(r) includes requirements for accidental release prevention regulations. EPA proposed its regulation on risk management planning on October 20, 1993. Its requirements apply to facilities that have more than a threshold quantity of a regulated substance in a process. As mandated by the CAA, the final rule requires facilities to develop and implement a risk management program that includes a hazard assessment of the off-site consequences of releases under worst case and alternate scenarios, a prevention program, and an emergency response program. Information about the program must be documented in a risk management plan that is submitted to a central location and made available electronically to states and local planing agencies as well as the public. On January 31, 1994, EPA promulgated a final rule on the substances and thresholds: 77 acutely toxic chemicals, 63 flammable gases and volatile flammable liquids, and Division 1.1 high explosive substances as listed by DOT. The final risk management planning regulations can be found at 40 CFR part 68. In the broadest sense, risk management planning relates to local emergency preparedness and response, to pollution prevention at facilities, and to worker safety. In a more focussed sense, these requirements build on OSHA's Process Safety Management Standard (issued on Feb. 24, 1992). They also draw from the chemical safety guidelines of the Center for Chemical Process Safety of the AIChE and similar standards of the American Petroleum Institute and Chemical Manufacturers Association. The elements of the prevention program include the following: Review and documentation of the plant chemicals, processes, and equipment; Detailed process hazard analysis to identify hazards, assess the likelihood of accidental releases, and evaluate the consequences of such releases; Development of standard operating procedures; Training of employees on procedures; Implementation of a preventative maintenance program; Management of changes in operation that may impact the safety of the system; Reviews before initial start-up of a process and before start-up following a modification of a process; Investigation and documentation of accidents; Periodic safety audits to ensure that procedures and practices are being followed. The final risk management planing regulation (40 CFR 68) defines the activities sources must undertake to address the risks posed by regulated substances in covered processes. To ensure that individual processes are subject to appropriate requirements that match their size and risks they may pose, EPA has classified them into three categories ("Programs"). Program 1 requirements apply to processes for which a worst-case release, as evaluated in the hazard assessment, would not affect the public. These are sources or processes that have not had an accidental release that caused serious offsite conseqences. Remotely located sources and processes using listed flammables are primarily those eligible for this program. Program 2 requirements apply to less complex operations that do not invlove chemical processing (e.g., retailers, propane users, non-chemical manufacturers, and other processes not regulated under OSHA's PSM Standard). Program 3 requirements apply to higher risk, complex chemical processing operations and to processes already subject to the OSHA PSM. The OSHA PSM Standard (29 CFR 1910.119) reflects the key elements that the petrochemical industry, trade associations, and engineering societies have deemed essentail to safe management of hazardous substances for complex, chemical-processing operations. EPA has adopted OSHA's PSM requirements as the Program 3 prevention program, with only minor changes in terminology. With few exceptions, processes assigned to Program 3 are already subject to the OSHA PSM Standard; the remaining Program 3 processes are in industry sectors that have a significant accident history. For more information, contact the Emergency Planning and Community Right-to-Know Hotline at: 1-800-424-9346 or visit the CEPPO Home page  Back to Regulatory Compliance Self-Assessment
Copyright © 1999 www.njit.edu/njtap All rights reserved.			New Jersey Technical Assistance Program for Industrial Pollution Prevention · 138 Warren Street · Newark, NJ 07102-1982 · Phone: 973-596-5864 · Fax: 973-596-6367 · Email: njtap@megahertz.njit.edu