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  • Implementing agency liability for accidents at stationary sources

    Are implementing agencies for the risk management program liable for an accident that occurs at a covered stationary source? No. The primary responsibility for accident prevention is the facility's. The Clean Air Act does not assign any liability to the implementing agency (i.e., EPA or state or local government agencies)…

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  • Adding chemicals to list of regulated substances

    CAA §112(r)(3) provides EPA the authority to amend the list of regulated substances. Does EPA expect to add chemicals to the list of regulated substances in the near future? At this time, EPA does not expect to add any chemicals to the list of regulated substances. The statute, however, requires…

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  • Are there any RMP recordkeeping requirements?

    Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200).

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  • Will we be audited if a member of the public requests an audit of our facility?

    The implementing agency will have to decide whether to respond to such public requests. EPA’s intention is that part 68 implementation reflect that hazards are primarily a local concern.

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  • Guidance for on-site compliance evaluations under CAA §112(r)

    CAA §112(r)(6)(L) provides employees and employee representatives with rights to participate in EPA CAA §112(r) compliance evaluations. What formal guidance is available from EPA regarding the involvement of facility employees and employee representatives in EPA and delegated Agency on-site compliance evaluations conducted under CAA §112(r)? The EPA Office of Land…

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  • CAMEO Training Opportunities

    Where can I find CAMEO training opportunities? Information on CAMEO training and events is available at the EPA CAMEO website.

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  • Time Frame to Submit RMP Emergency Contact Information Changes

    How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month…

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  • RMP Guidance Materials

    Does EPA provide guidance materials to assist facilities who must comply with the Risk Management Program (RMP) requirements? Yes. EPA developed the following guidance documents and checklists to assist the regulated community in understanding the Risk Management Program rule: General Risk Management Program Guidance Supplemental Risk Management Program Guidance for…

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  • Under the Lead Renovation, Repair and Painting (RRP) Rule, what type of container is adequate for on-site storage of debris? 

    At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…

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  • CFAT Impacts on EPCRA and RMP

    The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act §112(r)…

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