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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-N-0239
April 28, 2014
Why We Did This Review
While conducting work as part
of an Office of Inspector
General evaluation of a
U.S. territory's implementation
of its delegated Clean Air Act
programs, we obtained and
analyzed data on imports of
hazardous substances to the
United States. We obtained this
data to help us determine
whether facilities may have
hazardous substances onsite in
amounts that would require
them to prepare risk
management plans (RMPs)
under the Clean Air Act
Section 112(r) risk
management program.
The work performed and
disclosed in this report does not
constitute an Office of Inspector
General evaluation conducted
in accordance with generally
accepted government auditing
standards issued by the
Comptroller General of the
United States.
This report addresses the
following EPA theme:
• Taking action on toxics and
chemical safety.
For further information,
contact our public affairs office
at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2014/
20140428-14-N-0239.pdf
Chemical Import Data May Help EPA Identify Facilities
That Need to File or Update Risk Management Plans
What We Found
Import data showed large shipments of
anhydrous ammonia and chlorine to ports
and facilities across the United States for
which facilities may need to prepare an
RMP or revise their RMPs. We identified
four types of situations that could indicate
facilities need to prepare or revise RMPs to
reflect large amounts of regulated
chemicals, as follows:
Given the potential public harm
if an accidental release were to
occur at a facility using or storing
substances at or above threshold
levels, the U.S. Environmental
Protection Agency may want to
use chemical import data to help
determine whether facilities have
a sufficient RMP in place.
•	Imports of chemicals above the reporting threshold to facilities with no RMP.
•	Return shipments of large empty containers to facilities with no RMP.
•	Imports of chemicals in amounts greater than the amount reported in the
facility's RMP.
•	Large shipments of regulated chemicals for which consignee information
was not available.
Additional analyses and/or onsite inspections are needed to determine whether
the facilities described above are complying with risk management program
requirements. Because of the sensitive nature of the information we developed,
we will provide the agency with our detailed analyses separately from this report.
If facilities subject to the risk management program are not preparing RMPs, they
may not be taking adequate measures to prevent accidents or mitigate the
consequences of such accidents to the public. Further, without a plan detailing
the chemicals located onsite and the risks associated with those chemicals, first
responders may not have the information necessary to safely and effectively
respond to a chemical accident.
We make no formal recommendations, but we encourage the agency to use the
information we developed to determine whether the facilities we identified need to
prepare or revise RMPs. We also encourage the agency to assess whether it
should develop procedures for using import and export data as a method for
identifying potential RMP non-filers.

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