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  • Minimum and Maximum Distance to Endpoint

    The Chemical Accident Prevention Provisions require the completion of a worst-case release scenario analysis (40 CFR §68.25). This analysis includes estimating the greatest distance to endpoint as defined by the parameters in §68.22. Is there a required minimum or maximum distance for the distance to endpoint in the worst case…

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  • Are facilities that have received ISO 14001 certification exempt from audits?

    If we have been audited by a qualified third party, for ISO 14001 certification or for other programs, are we exempt from audits? No. However, you may want to inform your implementing agency that you have gained such certification and indicate whether the third party reviewed Part 68 compliance as…

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  • Will risk management plan (RMP) submissions be subject to audits?

    Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits? Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency…

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  • Applicable requirements for Title V air permits

    Under the CAA, air permitting authorities must ensure that sources are in compliance with applicable requirements to issue a permit. Do the CAA §112(r) provisions constitute applicable requirements for Title V air permits? Yes. Section 112(r) is an applicable requirement for CAA Title V air permits under 40 CFR Parts…

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  • Atmospheric conditions used for off-site consequence analyses

    What atmospheric conditions must a source assume when performing the offsite consequence analyses required under 40 CFR Part 68, Subpart B? For the worst-case release analysis, 1.5 meters per second wind speed and F atmospheric stability class must be assumed, unless the stationary source owner or operator can demonstrate that…

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  • Program levels and the difference in worst-case release analysis requirements

    The preamble to the Risk Management Program Rule ( 61 FR 31668; June 20, 1996 ) states that "one worst-case release scenario will be defined to represent all toxics, and one worst-case release scenario will be defined to represent all flammables held above the threshold at the source" ( 61…

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  • Voluntary Implementation and Submission of RMP

    Pursuant to the risk management program regulations in 40 CFR Part 68, owners and operators of a stationary source that have more than a threshold quantity of a regulated substance in a process must implement and submit a risk management plan (RMP) to EPA. If the risk management program regulations…

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  • EPA identification of facilities failing to submit RMPs

    What does EPA do to identify facilities that did not file an initial or updated RMP but were required to do so? EPA examines a number of existing databases to identify potential non-filers. If anyone has any information about any facility that may be subject to the Risk Management Program…

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  • Methods to identify affected populations

    As part of the risk management program, a facility owner or operator must prepare an off-site consequence analysis (OCA) and estimate in the risk management plan (RMP) the residential population within the geographical area that could be affected by the hypothetical worst-case or alternative releases that the facility has analyzed…

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  • Determining a facility's latitude and longitude

    A facility subject to the risk management program requirements in 40 CFR Part 68 must specify its latitude and longitude coordinates in Section 1.5 of the risk management plan (RMP). What tools are available to accurately determine a facility’s latitude and longitude? The owner or operator of a regulated facility…

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  • If a facility changes owners, but the manufacturing operations have not changed, are they REQUIRED to update their RMP?

    Yes. If the owner of a facility changes, the RMP on record with EPA should reflect the current owner by the date ownership changes or responsibility for operation of the facility is transferred. You do not have to update each section of your RMP if the only thing that has…

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  • When must RMPs be submitted, updated, and corrected?

    When must the risk management plans (RMPs) required under 40 CFR Part 68, Subpart G, be submitted? When are updates and corrections required? Compliance with the risk management program requirements (including submission of an RMP) is required by the date on which a regulated substance first becomes present above a…

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  • Comprehensiveness and format of a management system

    What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning…

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  • Complying with process safety information (PSI) resulting from new and updated recognized and generally accepted good engineering practices (RAGAGEP)

    My Program 3 process was built prior to new and updated recognized and generally accepted good engineering practices (RAGAGEP) for my industry. Do I need to implement the new industry practices to comply with process safety information (PSI) requirements under 40 CFR §68.65? EPA expects owners and operators to regularly…

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  • Consolidated List of Chemicals Subject to EPA Regulatory Programs

    EPA implements a number of regulatory programs that use specific chemical lists as part of the process to determine reporting applicability. Is there a consolidated list of chemicals that are subject to EPA programs? The Consolidated List of Chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive…

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