Where Can I Get More
Information?
If you have access to the Internet, you can get
copies of the rule and a wide variety of
technical assistance materials at the home
page of EPA's Chemical Emergency
Preparedness'and Prevention Office
(http://www.epa.gov/swercepp/).
You also may obtain copies of these materials
as well as answers to your specific questions
from EPA's hotline at (800) 424-9346 during
normal business hours.
The International Warehouse Logistics
Association can be reached at:
1300W. HigginsRoad
Suite 111
Park Ridge, IL 60068-5764
(847)292-1891
The full text of the rule can be found in Title
40 of the Code of Federal Regulations (40
CFR part 68), which is available at most
public libraries.
RMP SERIES
EPA's Risk
Management
Program
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How Does It Affect Chemical
Warehouses?
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Does This Apply to Me?
What's It All About?
Compliance Tips
Under a new EPA chemical accident
prevention rule, some chemical warehouses
will have to implement a risk management
program and file a risk management plan
(RMP) with EPA by June 21, 1999. If you
handle or store any of the following above the
threshold quantities, you are likely to be
subject to this rule:
Chemical
Boron trifluoride
Cyclohexylamine
Diborane
Epichlorohydrin
Ethylenediamine
Formaldehyde
Hydrazine
Toluene 2,4- and 2,6-
diisocyanate
Threshold Quantity
5,000
15,000
2,500
20,000
20,000
15,000
15,000
pounds
pounds
pounds
pounds
pounds
pounds
pounds
10,000 pounds
Flammable chemicals such as acetylene,
dimethylamine, methylamine, pentane, and
propane each have a threshold quantity of
10.000 pounds. (The use of propane as a fuel
Ui covered by the rule.) If you have other
chemicals at your facility, you can get a
complete list of substances regulated under
this rule and their thresholds from EPA.
The risk management program rule (also
known as Clean Air Act section 112(r), the
RMP rule, or part 68) is designed to prevent
serious chemical accidents that could affect
public health and the environment and to
improve the response to any accidents that do
occur.
The rule requires covered facilities to develop
and to implement an integrated system to
identify hazards and manage risks. If you are
subject to this rule, you must analyze worst-
case releases, document a five-year history of
serious accidents, coordinate with local
emergency responders, and file a risk
management plan with EPA. If your worst-
case release could affect the public, you also
must analyze more realistic alternative
scenarios and develop and implement a
prevention program that includes, among
other steps, identification of hazards, written
operating procedures, training, maintenance,
and accident investigation. If your employees
respond to accidental releases, you must
implement an emergency response program.
The RMP you submit to EPA will summarize
your program and will have to be made
available to the public.
The good news is that many warehouses
already are complying with many of the
prevention requirements because these steps
are part of the way you operate safely. If you
are subject to the OSHA Process Safety
Management Standard, you are likely to be in
compliance with almost all of the prevention
program requirements and may need to take
no other steps to satisfy this part of EPA's
rule. If you already have an emergency
response plan, you are likely to be in
compliance with that part of EPA's rule as
well.
Besides helping you prevent accidents, the
rule can improve the efficiency of your
operation by ensuring that your workers are
trained in proper procedures and by using
preventive maintenance to reduce equipment
breakdowns.
EPA is working with the International
Warehouse Logistics Association (IWLA) to
develop a guidance document specifically for
warehouses that will help you understand the
requirements as they relate to your
operations. The warehouse guidance will
make compliance less burdensome by
providing industry-specific information and
analyses.
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