Under the Clean Air Act, facilities that present a high risk of chemical accidents, including those engaged in industries such as chemical manufacturing, paper manufacturing, and warehousing and storage, are required to prepare and implement a “Risk Management Plan” (RMP). In particular, if a facility holds more than a threshold quantity amount of a regulated substance in a process, an RMP must be submitted to the EPA and updated every five years.
Certain changes may also trigger updating an RMP sooner, for example, if EPA adds a new chemical to the list of regulated substances, a revised RMP must be submitted by a facility within three years of that chemical’s list date.
EPA’s goal of requiring facilities to prepare an RMP is two-fold: to prevent a chemical accident and to prepare for a chemical accident. To that end, EPA’s regulations require RMPs to contain a wide variety of information and analyses relating to assessing the hazards at a facility, assessing a facility’s accident history, evaluating worst-case scenarios, developing an emergency response program, and implementing safety precautions, training and monitoring geared toward prevention.
In an effort to “further protect…
