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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 distributors =
• will have to implement a risk management :
program and file a risk management plan ^
(RMP) with EPA by June 21,1999. If you *
handle, produce, or store any of the following i
above the threshold quantities, you are likely -1
to be subject to this rule: I
Chemical
Threshold Quantity §
Anhydrous ammonia 10,000 pounds
Chlorine 2,500 pounds
Formaldehyde 15,000 pounds
Aqueous hydrochloric acid 15,000 pounds
(concentration 37% or greater)
Hydrofluoric acid 1,000 pounds
Nitric acid 1,000 pounds
Propylene oxide 10,000 pounds
Other acutely toxic chemicals have threshold
values ranging from 1,000 pounds to 20,000
pounds. Flammable chemicals such as
dimethylamine, isopropyl chloride,
isopropylamine, and propane each have a
threshold quantity of 10,000 pounds. (The
use of propane as a fuel js covered by the
rule.) If you have other chemicals at your
facility, you can get a compljetejlist of
substanceslregulated
isbuleand their i
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 isumrnarize
your program: and will have toLbe madb'! '
available to the public.
The good news is that many chemical •
distributors 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 OS HA 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 National
Association of Chemical Distributors
(NACD) to develop a guidance document
specifically for chemical distributors that will
help you understand the requirements as they
relate to your operations. The chemical!
distributor guidance will make compliance
less burdensome by providingiindu^ryj-i• i;i
specific information ar^d anajysesj| = :U•:::
-< J - K: « ;Mi ME;; ::;::;::; :
•» X , .--.. iS, ,i i, ,r i i,, ,,; ,,;iii, , ,
!fil t
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