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Risk Management Programs and Plans

First, it is important to identify a terminology issue. The EPA uses two terms that are interconnected that have the same acronym. These are the Risk Management Program and the Risk Management Plan. To differentiate between the two, the Risk Management Program will be abbreviated as “RMP”. The Risk Management Plan will be abbreviated as “RMPlan”. It is important to understand the difference as discussed below.

EPA required facilities to develop and maintain a Risk Management Program (RMP) for all covered facilities (those with over 10,000 lbs of ammonia) in 1999.

Fortunately, the EPA basically adopted the OSHA PSM program and added the RMP requirement to extend the protection to the population at large and not to just the employees of a facility.

The purpose of requiring a RMP was to summarize, document and communicate the essentials of an RMP to the EPA and other relevant state and local agencies.

The requirements for these plans were as follows:

1. Identify the covered process and chemicals involved
2. Determine a program level (1, 2 or 3) which then determined what the regulatory requirements for that facility’s plan would be.
3. Develop a management system to maintain and mange the plan.
4. Describe the relationship between the ammonia refrigeration system as operated and as it relates to the facility and the local community
5. Develop an Off-Site Consequence Analysis (OCA) involving a “worst case scenario” release and an “alternative case scenario” release.
6. Identify, describe and document any releases that have occurred in the last five (5) years.
7. Describe in detail the Preventative Program (mirroring the OSHA PSM regulation).
8. Develop and implement an Emergency Planning and Response program to quickly address any emergencies or releases.

Part of the RMP is to create and submit (or resubmit) a Risk Management Plan (RMPlan) to the EPA.  The RMPlan is essentially a ‘survey’ of information related to the PSM program and the Risk Management Program.  It is created using an on line program called RMP*eSubmit.  Prior to being able to access RMP* eSubmit, the facility must first register with the EPA’s Central Data Exchange (CDX) system (which allows on line access/editing capability).  Every facility maintaining over 10,000 pounds of anhydrous ammonia is legally required to submit an RMPlan to the EPA.  Fines for failure to do so are harsh.

The RMPlan must be resubmitted (essentially an update of information) at least every five (5) years.  In addition, if a facility modifies their ammonia system and introduces new types of equipment not discussed/addressed during their most recent Process Hazard Analysis (PHA), the RMPlan must be revised within six (6) months of the introduction of ammonia to that newly added equipment.  Finally, if a facility is modified involving a significant increase in ammonia charge, the RMPlan requires resubmittal (even if the equipment added via the change operates identically to equipment currently at the facility).  As a rule of thumb, if you are expanding your facility by adding new rooms or significantly modifying existing rooms, an RMPlan revision should be performed.

For further information regarding Risk Management Programs, Risk Management Plan submittals, and/or other PSM related questions, please contact ComPSM, Incorporated.