Chemical Accident Prevention is high on everyone’s priority list. The EPA even has a rule for it. The Risk Management Plan (RMP) Rule (40 CFR Part 68) governs accident prevention under Section 112(r) of the Clean Air Act Amendments. The “RMP Rule” established regulations that facilitate accident prevention at facilities that use certain highly hazardous chemicals listed in the regulation. For example, many facilities that use anhydrous ammonia are required to prepare and implement an RMP at their location, and must submit the RMP to the EPA every 5 years. Whoa, you say. What’s in an RMP? An RMP is a set of documents and procedures that govern the following actions at a facility when that facility has the highly hazardous chemicals in a process in quantities above a Threshold Quantity. For ammonia refrigeration the threshold is 10,000 pounds.
Why would a facility want to prepare an RMP? First of all, because these plans provide your local police, fire and emergency response personnel with information needed so that they can respond to an incident at your facility in the most effective way possible. And, Secondly, because these plans must be submitted to EPA. They must also be resubmitted every five years. FUN FACT Did you know that the Environmental Protection Agency implements the Risk Management Plan (RMP) Rule in Michigan – not the Michigan Department of Environmental Quality? The August 9, 2018 Federal Register provided OSHA’s latest amendments of the Beryllium rule (29 CFR 1910.1024) and delayed certain compliance deadlines. We think its helpful for the compliance deadlines to be outlined in chronological order. So we made a list for you. Below are the compliance dates (bolded) for the OSHA rule. If the MIOSHA dates are the same or different, it is noted. Listed below the compliance dates are the various paragraphs of 1910.1024 that are affected by the bolded compliance dates: March 12, 2018 – same for MIOSHA This is the compliance date for obligations contained in paragraphs (c), (d), (g), (k), and (l) of this standard.
December 12, 2018 – MIOSHA Part 340 is March 12, 2018. The amended rule sets this date as the compliance date for “all other obligations” of this standard such as:
March 11, 2019 – same for MIOSHA For paragraph (i) Hygiene Areas and Practices, the following requirements have been postponed until this new compliance date:
March 10, 2020 – same for MIOSHA For Engineering Controls required by paragraph (f) this is the new compliance date. However, It is believed that the intent here is for companies to comply with the non-engineering control portions of this section such as:
We’ll keep you updated on more OSHA and MIOSHA updates of this and other standards in future issues. Did you think that once you “complete” your Risk Management Planning (RMP) and Process Safety Management (PSM) programs there is no more work to be done? Often, regulatory requirements are thought of as one and done. You prepare the document and its done, you don’t have to look at it again for five years. Not in this case. These programs require vigilance, especially if the processes at your facility often change. For starters, both PSM and RMP include periodic actions that must be completed regularly. Here’s an abbreviated listing:
So, as you can see with this truncated list of periodic requirements, there is a lot to do after the main part of the program is established. I will say this, it gets a little easier as personnel understand what is expected of them and adopt a PSM/RMP safety culture. One final thought. Remember to document all of your reviews and date all of your changes. The old saying still holds true. If it wasn’t documented and you can’t prove a review took place, it didn’t happen. Beginning July 1, 2018, all hazardous waste shipments from small and large quantity hazardous waste generators, and all shipments of polychlorinated biphenyl (PCB) waste, requiring a uniform manifest, must be submitted to the U.S. EPA for tracking in the online e-Manifest system. The receiving TSDF is responsible for submitting the e-Manifest information it receives to the U.S. EPA. It is also responsible for paying any e-Manifest processing fees due to the U.S. EPA following deployment. To ensure a smooth transition, generators are encouraged to review e-Manifest resources shared with them by their TSDF and to review resources on the MDEQ and USEPA websites. Highlights for Generators
The eManifest online system is located in the USEPA CDX online system under RCRA Info and is currently available to explore. You will need to open a CDX account if you don’t already have one. There is a Youtube video from USEPA that walks you through a fictitious site and may be helpful. To get more information, check out the MDEQ and USEPA resource pages, or contact SRM for assistance. By now you should be knee deep in assembling information reviewing data and getting ready to prepare and submit your Q1 reports.
OSHA 300A Logs – Your OSHA Log Posting is due February 1st. Make sure you have re-reviewed some 2016 incidents with your incident investigation team to ensure you have all the information you need and that it is still current. Sometimes reporting information changes weeks and even months after an incident so you want to be sure days away, transfer and other information is still correct. Hazardous Waste Biennial Report – Review your waste shipping records to verify you have all the original signed manifests, LDR documents and waste characterization files for all wastes generated during 2016. Do a quick generator status check to determine whether or not your generator status has changed. Tier 2 Reports – Has your company started any new processes this past year or started storing new chemicals on site? If so, determine the quantities you now store and how the materials are managed. This is a good time to update your chemical inventory. Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual and annual reports to submit. It is a good idea to check in with the staff responsible for collecting the data to ensure it will be available when needed and it is accurate. Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors in your home, the new year is a good time to check your online access user names and passwords to make sure they are current and still work. Some agencies require you to change your password annually. The new year is a good time to make sure that everyone involved in the reporting process still knows their login information. Getting these items resolved now will help avoid headaches as you approach reporting deadlines. If you have questions, give us a call and we will be happy to help.
|
|