What is the Risk Management Plan?

In the United States, the prevention and control of accidental releases of chemicals is regulated by the Environmental Protection Agency (EPA) under 40 CFR Part 68. These regulations work to prevent the accidental release of chemicals that are hazardous to human health or the environment, and to control the severity of any releases that may occur.

Any establishments that stores, manufactures, or uses more than a threshold quantity of a regulated substance must implement a Risk Management Plan (RMP). This RMP must be submitted no later than the date on which the regulated substance is present above threshold levels. The RMP must be updated and re-submitted every five years, or within six months of a change. The EPA’s “RMP*eSubmit” system can be used to prepare and submit an RMP online.

The EPA divides regulated processes into three programme levels:

Programme 1 – The process has not had an accidental release of a regulated substance with offsite consequences for five years, and the worst-case scenario would not have impact on the public. Programme 1 registration includes:

  • A single RMP that reflects all processes
  • Analysis of the worst-case scenario for each process
  • Completion of a five-year accident history for each process
  • Ensuring that response actions have been coordinated at least annually with the local emergency agencies
  • A Certification statement in the RMP

Programme 2 – The process is not eligible for Programme 1 or Programme 3. Programme 2 registration includes:

  • A single RMP that reflects all processes
  • Development and implementation of a management system
  • Conducting a hazard assessment, including a worst-case scenario and an alternate, more likely, scenario
  • Completion of a five-year accident history for each process
  • Ensuring that response actions have been coordinated at least annually with the local emergency agencies
  • Development and implementation of an emergency response programme, including conducting exercises annually
  • Implementation of prevention steps that include up-to-date:
    • Safety information
    • Operating procedures
    • Training and re-training
    • Maintenance of process equipment
    • Compliance and third-party audits
    • Incident investigations

Programme 3 – The process is not eligible for Programme 1 and is subject to either the Occupational Safety and Health Administration (OSHA) process safety management standard, or to certain North American Industrial Classification System (NAICS) codes. Programme 3 registration includes:

  • A single RMP that reflects all processes
  • Development and implementation of a management system
  • Conducting a hazard assessment, including a worst-case scenario and an alternate, more likely, scenario
  • Completion of a five-year accident history for each process
  • Ensuring that response actions have been coordinated at least annually with the local emergency agencies
  • Development and implementation of an emergency response programme, including conducting exercises annually
  • Implementation of prevention steps that include:
    • Safety information
    • Employee participation
    • Procedures for contractors
    • Pre-startup safety review
    • Operating procedures
    • Training and re-training
    • Maintenance of process equipment
    • Hot work permits
    • Procedures of management of changes
    • Compliance and third-party audits
    • Incident investigations