EHS Support was retained by a major chemical producer in the U.S. to update its existing Risk Management Plan (RMPlan) on file with the U.S. Environmental Protection Agency (USEPA). The RMPlan had not been updated for the past 12 years. Additionally, EHS Support was tasked with putting together a comprehensive Risk Management Program (RMP) for the facility designed to reduce the risks of incidents and injuries from hazardous chemicals stored at the facility.
EHS Support guided the client through the USEPA website to re-establish its account (login info, access to RMP eSubmit, current contact info, etc.). EHS Support assisted the client in updating the RMPlan, including the chemical list, by adding any new hazardous chemicals currently stored at the facility, removing chemicals no longer stored at the facility, and updating or developing worse case release scenarios (WRS) and alternate release scenarios (ARS), including impact mapping, for each regulated chemical on the list.
EHS Support also focused on developing a comprehensive RMP for the facility. The RMPlan document includes information submitted to USEPA in the RMP, along with details of the following programs developed to help reduce the risks of regulated chemical releases at the facility:
- Program applicability and levels
- Overview of inventories of regulated substances
- Accidental Release Prevention and Emergency Response Policies and Programs
- Off-site Consequence Analysis, including WRS and ARS, for each of the regulated chemicals
- Process Safety Information related to the handling and storing of hazardous chemicals
- Process Hazard Analysis (PHA) for each of the regulated chemicals
- Operating procedures related to the handling and storing of highly hazardous chemicals
- RMP training on RMP standards and operating procedures
- Mechanical Integrity Program
- Management of Change (MOC) Program
- Compliance Audit Review
- Incident investigation program
- Employee participation plan
- Hot Work Permit procedure
- Contractor safety procedures
- Emergency coordination with primary local agency
At the completion of the project, EHS Support provided the client: 1) a current RMPlan on file with USEPA as required; 2) a comprehensive RMP designed to reduce risks from the handling and storage of highly hazardous chemicals; and 3) a framework for staying current with compliance audits (every three years), tracking changes through MOC, revalidating PHAs (every five years), and submitting updates to USEPA (every five years).