EPA 40 CFR Part 68
When Congress passed the Clean Air Act Amendments of 1990, it required the Environmental Protection Agency (EPA) to publish regulations and guidance for chemical accident prevention at facilities using extremely hazardous substances. The Risk Management Plan Rule (RMP Rule) was written to implement these amendments, and requires companies of all sizes that use certain flammable and toxic substances to develop a Risk Management Program, which includes:
- A hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases;
- A prevention program that includes safety precautions and maintenance, monitoring, and employee training measures; and
- An emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies should an accident occur.
The Risk Management Program is about reducing chemical risk at the local level. This information is useful to citizens in understanding the chemical hazards in communities, encouraging communication between industry and the public and improving response times and overall accident prevention.
Impact
EPA 40 CFR part 68 includes a List of Regulated Substances under section 112(r) of the Clean Air Act, including their synonyms and threshold quantities (in pounds) to help assess if a process is subject to the RMP rule. Any owner or operator of any source that has more than the threshold quantity of hazardous substances is subject to this regulation. Individual states which have elected to take part in the Clean Air Act, Section 112(r) program, may have additional requirements for the federally listed chemicals. Regular hazard reviews are necessary in order to satisfy the requirements efficiently and ensure the safety of employees, the environment and the public.
Challenge
Many companies are managing risk assessment documents in disparate systems or even paper-based systems making it difficult to leverage data across divisions and teams. Legacy risk management processes, and aging, outdated systems and infrastructure can increase a facility’s exposure to risk unnecessarily. In addition, many facilities that deal with highly hazardous chemicals have an inconsistent risk culture and lack of a consistent, standardized format for identification, analysis and mitigation.
The Dyadem Solution
One of the best and most productive means of streamlining compliance is to deploy a central framework that can act as a Process Safety Management (PSM) compliance platform for the company. A compliance platform can give one click access to documents, data assurance maps & workflows, integrated EH&S systems, real-time data, internal reporting, dashboards, contractor information, access to regulatory organizations and citations, KPI metrics, and much more. Having a central location to access PSM information systems makes accident prevention more efficient, and response times faster to any incidents that may occur.
The Stature enterprise risk management platform is built on the principles of continuous improvement, providing seamless communication from the operator up to the executives and customized dashboards and reporting for every level of the company. Its Risk Assessment, Management of Change, Incident Management and Action Tracking modules support multiple workflows that can be configured to any corporate standards and provide a global risk register of all hazards across the organization. Gaining this critical risk visibility, in real-time, is crucial for accident prevention in facilities that deal with substances that pose a threat to their employees and the public at large.
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