EPA Risk Management Program
Risk Management Plan (RMP) is a regulation promulgated by the Environmental Protection
Agency (EPA) for Chemical Accident Release Prevention (40 CFR 68). This federal regulation
was mandated by section 112(r) of the Clean Air Act Amendments of 1990. The regulation
requires facilities to develop and implement proper risk management program to mitigate risk, in
term of frequency and severity of chemical plant incidents1.
The EPA requires a performance-based approach towards compliance with the Risk
Management Program regulation. Included in the RMP are description of the hazard assessment,
prevention program, and the emergency response program. Environmental Protection Agency
(EPA) Risk Management Program (RMP) also describes a methodology to conduct a process
hazard analysis and it is included in section 40 CFR 68.67.
RMP is mandatory for facilities that use more than a certain threshold quantity of regulated
highly hazardous chemicals. These facilities submit its RMP to the EPA and subsequently the
RMP is made available to governmental agencies, the state emergency response commission, the
local emergency planning committees, and communicated to the public. In general, the Risk
Management Program composes of four requirements:
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Hazard assessment
Prevention program
Emergency response program
Documentation that is maintained on the site and submitted to federal, state and local
authority and sometimes also shared to the local community.
Each program of Risk Management Program is tailored to include at least one of the previous
four elements, as the requirement of the elements will vary on different facility. Hazard
assessment is a consequence analysis for all potential hazardous chemical releases, including
worst-case scenario and history of releases at the facility. The worst case release is defined 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.
1
Crowl, D. A, Louvar J. F, Chemical Process Safety Fundamental with Application, U.S.
Prentice Hall, 2002.
The EPA requires hazard assessment to analyze consequence of the following worst-case
scenario:
1. A single worst-case release scenario is analyzed for all covered flammable materials on the
site and only one flammable substance is analyzed for other more likely scenarios.
2. A single worst-case release scenario is analyzed for all toxic substances on the site and more
likely releases are analyzed for each toxic substance available and covered by the regulation.
The Risk Management Program requires only the analysis of consequence and not the
probability of an incident scenario. Therefore, the analysis is not a true determination of risk
which is a join of probability and consequence.
The second requirements, Prevention program has 11 elements which are relatively similar to
PSM standards. In many ways the EPA- RMP is very similar to OSHA PSM because the EPA
attempted to have the same requirements wherever possible as PSM-OSHA. However, difference
exists because EPA and OSHA have different responsibilities. RMP is designed specifically for
off-site people and environment protection whereas PSM is designed specifically for on-site
people protection. Comparison of prevention program between Process Safety Management
(OSHA) and Risk Management Plan (EPA) is shown in Table 1.
Table 1. Prevention program of Process Safety Management (OSHA) and Risk Management
Plan (EPA)2
Process Safety Management (OSHA)
Process safety information
Process Hazard Analysis
Operating Procedures
Employee participation
Training
Contractors
Pre-Startup Safety Review
Mechanical Integrity
Hot Work permit
Management of Change
Incident Investigation
Emergency Planning and Response
Compliance Audits
Trade Secret
(No equivalence)
2
Idem as 1
Risk Management Plan (EPA)
Process safety information
Hazard evaluation
Standard operating procedures
(No equivalence)
Training
(No equivalence)
Pre-start up review
Maintenance
(No equivalence)
Management of change
Accident investigations
Emergency response
Safety audits
(No equivalence)
Risk assessment
The third requirement is emergency response program, which describe the steps needed in
response to incidental releases of hazardous materials. The program also establishes procedures
for notifying the local community and emergency response agencies.
The fourth requirement is documentation. This part of RMP is pretty self explanatory.
Steps to check for coverage and compliance requirements3
Facility may check to determine coverage and compliance requirements under the EPA Risk
Management Program. There are four steps to follow, which are:
1. Check the list of chemical from the EPA Risk Management Program to determine if any
of the chemicals are present in the facility and above the threshold quantity at any time.
The threshold quantity determination is considered at the maximum that could be on site
at any given time. Other considerations are proximity, interconnectivity concentration,
and so on. In addition to the chemical list, EPA also provides rules for mixture and effect
of dilution. If the threshold quantity does not exceed the list, then the facility is not
subject to the EPA risk management program and steps 2-4 may be ignored.
2. If any of the RMP listed chemicals are confirmed to be present or above the threshold
quantity, the facility must perform a worst-case scenario analysis. The If the impact zone
from worst-case scenario does not contain any public receptors, the facility has had no
incidents in the last 5 years, and the facility’s emergency response plan is coordinated
with local emergency response officials; then the facility belongs in Program 1.
3. If the facility cannot claim coverage under Program 1and the facility is classified in any
of the industrial classification codes or the facility is covered by the OSHA PSM
regulation, then the facility belongs in Program 3 and must comply with Program 3
requirements.
4. If the facility does not belong in Program 1 or Program 3, then by default the facility is
required to comply with Program 2 requirements.
Table 2 shows all programs included in the EPA Risk Management Program. A significant
characteristic of the EPA Risk Management Program is that the regulation provides a tiered
program based on the risk and incident history of the facility. The regulation recognizes the fact
that one size does not fit all and the risk management program is based on a three-pronged
approach. First, the hazard assessment provides information about potential off-site
3
Lee’s Loss Prevention in The Process Industries Vol.1, Vol.2 and Vol.3 Hazard Identification, Assessment and
Control 3rd Edition, Elsevier, 2004.
consequences and the incident history of the facility. The prevention program and the emergency
response program are then developed based on the hazard assessments. It should be noted that
the prevention program requirements under Program 3 mirror the OSHA PSM program
requirements.
Table 2. Eligibility criteria and compliance requirements for different program levels EPA’s Risk
Management Program regulation4
Program1
Program 2
Program 3
Program Eligibility Criteria
No offsite accident history
Process not eligible
Process is subject to OSHA
for program 1 or 3
PSM (29 CFR 1910.119)
Process is SIC code 2611,
2812, 2819,
2821, 2865, 2869, 2873,
2879, or 2911
No public receptors in
worst-case circle
Emergency response coordinated
with local responders
Program Requirements
Hazard assessment
Hazard assessment
Hazard assessment
Worst-case analysis
Worst-case analysis
Worst-case analysis
5-year accident history
Alternative releases
Alternative releases
Certify no additional steps needed 5-year accident history
5 -year accident history
Management program
Management program
Document management
Document management
system
system
Prevention Program
Prevention Program
Safety information
Process safety information
Hazard review
Process hazard analysis
Operating procedures
Operating procedures
Training
Training
Maintenance
Mechanical integrity
Incident investigation
Incident investigation
Compliance audit
Compliance audit
Management of change
Pre-startup safety review
Contractors
4
Idem as 3
Emergency response
program
Develop plan and
program
Employee participation
Hot work permits
Emergency response
program
Develop plan and program