We offer RMP Consulting services for EPA’s Risk Management Program (RMP) to ensure guaranteed compliance.
Companies that handle certain highly hazardous chemicals in excess of threshold quantities must comply with EPA’s RMP rule, 40 CFR Part 68. EPA’s RMP rule uses several elements of OSHA’s PSM standard and applies it to protection of the public and the environment rather than employees as is the case with OSHA.
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.
WHY RMP CONSULTING SERVICES
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 RMP Consulting expertise in developing and maintaining their RMPs.
RMP regulations prevent accidental releases of substances that can cause serious harm to the public and the environment from short-term exposures and to mitigate the severity of releases that do occur.
RMP requirements apply to an owner or operator of a stationary source (facility) that operates one or more “covered processes”, i.e., processes which contain greater than the defined threshold quantity of at least one regulated substance. Facilities that operate one or more covered processes must develop and implement a risk management program that is specifically tailored to the hazards present within each covered process and the potential severity of the offsite environmental and public health impacts of a release, should one occur.
RMP REQUIREMENTS
- Developing and implementing a Management System
- Conducting Hazard Assessment
- Developing and implementing a Prevention Program
- Developing and implementing an Emergency Response Plan
- Submitting Risk Management Plan
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.
Because RMP and PSM deal with the very real dangers of an accidental chemical release, these are some of the most important compliance programs managed by site owners.
It is critical that your RMP program, including the RMP plan, is kept up-to-date and accurate as changes occur in your process, personnel, facility, or the community that surrounds it. Moreover, recent changes in the RMP regulation have introduced several new requirements through Safer Communities by Chemical Accident Prevention (SCCAP), including community outreach, third-party program auditing, and Root Cause Analysis (RCA).
With our RMP Consulting services, all of the RMP requirements can be fully met.
IMPORTANT DATES
- Annually – Operating procedures must be certified
- Every 3 Years
- PSM and RMP Compliance Audits must be completed
- Refresher training must be provided for personnel
- Every 5 Years
- Risk Management Plans must be revised and resubmitted to EPA
- Offsite Consequence Analysis modeling must be reviewed and resubmitted to EPA
- Process Hazard Analysis must be revalidated or redone
AUDITING
PSM and RMP management systems compliance audits are required every 3 years. The programs are performance based and therefore the quality of compliance audits is paramount to ensuring program compliance.
For facilities that require compliance with both regulations, a combined compliance audit is often the preferred method many clients. Third party audits can offer a different perspective from internal audits which may help highlight possible program gaps in documentation and applicability that may not surface when reviewing internal information. Furthermore, experienced third party auditors can leverage years of industry experience to offer suggested enhancements along with identifying any possible compliance gaps. Our RMP Consulting services meet the requirements of third party audits.
A combined PSM/RMP audit objectives include:
- To assess the site’s safety management system as it relates to the requirements established by OSHA’s Process Safety Management standard (29 CFR 1910.119)
- To assess the site’s safety management system as it relates to the requirements established by EPA’s Risk Management Program rule (40 CFR 68);
- To assess the site’s compliance with internal company specific PSM / RMP related requirements, and;
- To identify overall opportunities to improve and enhance the overall effectiveness of the site’s established process safety / risk management program(s).
RMP CONSULTING SERVICES WE OFFER:
We provide EPA’s RMP Consulting to cover all the requirements of PSM & RMP including development, management and auditing to achieve guaranteed compliance of the following requirements:
- RMP Applicability Analysis
- Offsite Consequence Analysis (OCA) using EPA Approved softwares including RMP*Comp, MARPLOT, ALOHA, CAMEO
- RMP plan Update and Submittal Assistance to comply with RMP*eSubmit
- RMP Program Supporting Documentation
- Audit Preparation and Support
- Compliance Auditing
- Process Hazard Analysis (PHA)
- Program 3 requirements including OSHA Process Safety Management (PSM) support for all 14 elements
Please contact us in case you have any queries about achieving RMP compliance:
