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  • What are dioxins and how common are they?

    Dioxins are found throughout the world in the environment. Dioxins are a result of industrial processes and other activities such as burning fuels like wood, coal, or oil. Dioxins are called persistent organic pollutants, meaning they take a long time to break down once they are in the environment.

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  • Hot Work Definition and Requirements

    Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…

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  • Do I have to conduct incident investigations of releases resulting from theft?

    The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…

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  • Do Program 1 processes have to complete a process hazard analysis?

    Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a…

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  • Is a hazard review synonymous with a process hazard analysis (PHA)?

    The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention…

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  • How often must compliance audits be performed?

    How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…

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  • I have heard about research being conducted by the University of Kentucky. What is the health tracking survey?

    University of Kentucky College of Public Health researcher Dr. Erin N. Haynes and her team received a grant from the National Institutes of Health (NIH) to conduct a long-term health study with and for the residents of East Palestine and the surrounding area. The first step is to learn more…

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  • What kind of screening does the East Liverpool City Hospital's East Palestine Clinic offer related to the train derailment?

    The screening tests are based on recommendations by specialists in toxicology to monitor anyone exposed to substances from the train derailment. The tests include urine and blood tests. A urinalysis is done that looks for problems involving the kidneys. The blood tests include a complete blood count (CBC) and a…

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  • Are any other tests ordered?

    There may be based on the evaluation by the physician or other healthcare provider. If a patient is having specific symptoms there may be other tests needed. For example, if a patient is short of breath, they may need to have a chest x-ray or other tests done to evaluate…

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  • Are there specific medical tests available for vinyl chloride?

    Medical tests to determine if you have been exposed to vinyl chloride include measuring vinylchloride in your breath but must be collected shortly after exposure. The test is not useful forvery low levels of exposure. Thiodiglycolic acid, which is a breakdown product of vinyl chloride detected in urine, can also…

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  • Does compliance under OSHA's PSM demonstrate compliance with the risk management program?

    The Clean Air Act Amendments of 1990 (CAAA) mandated the Occupational Safety and Health Administration (OSHA) to develop a regulatory program to protect workers from the risk of accidents that involve hazardous chemicals. OSHA promulgated its Process Safety Management Standard (PSM) on February 24, 1992 (57 FR 6356), codified at…

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  • Applicability of compliance audit provisions to non-prevention program elements

    I have a Program 2 covered process and a Program 3 covered process at my stationary source. I am required (by 40 CFR Section 68.58 and 40 CFR Section 68.79) to certify compliance with prevention program requirements every three years. These compliance audits specifically address the prevention program portions of…

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  • Does a five-year update satisfy the requirement to conduct a compliance audit?

    The owner or operator of a stationary source with a Program 2 or Program 3 process must conduct a compliance audit at least every three years to ensure compliance with the prevention program requirements and must revise and update the risk management plan (RMP) at least every five years (§§68.58…

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  • RMP Program Level 2 and 3 compliance audit frequency

    Pursuant to the risk management program regulations, facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Do regulated facilities have to perform the audits within exactly three years or can facilities perform the audits any time…

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  • Does a PHA for OSHA satisfy EPA's PHA requirement for Program 3?

    The risk management program regulations require that an initial process hazard analysis (PHA) for each Program 3 process be completed no later than June 21, 1999 (or by the time the process first has more than a threshold quantity of a regulated substance, if that occurs after June 21, 1999)…

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