Compliance Corner - RMP

​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.

• How the facility manages chemicals to keep them inside their containers and inside the process.
• How the facility plans to respond to a release of the chemical, including its emergency response procedures, should a release occur.
• Establishing the potential radius of impact that a chemical, once released, might have on the facility and the surrounding neighborhoods.

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.
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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?
 

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