Services - Risk Management Planning Services

RISK MANAGEMENT PLANNING SERVICES

Risk management programs include plans to detect and prevent or minimize the accidental release of regulated substances as stipulated in Section 112(r) of the Clean Air Act. In terms of applicability, all users of hazardous chemicals are required to plan for accidents as required by the general duty clause. The Risk Management Plan (RMP) for a specific site is a document which includes three basic elements:

	The Hazard Assessment;
	The Prevention Program; and
	The Emergency Response Program

The Hazard Assessment
The final RMP regulations require a Hazard Assessment that includes an evaluation of the potential range of releases for a facility, including worst-cause accidental releases, and the analysis of potential off-site consequences. It also requires documentation of an applicable facility's five-year Accident History.

The Prevention Program
A key element of the Prevention Program is the Hazard Assessment. This includes an analysis using a recognized technique such as HAZOP or What If/Checklist Analysis to review all processes which contain more than threshold quantities of regulated substances at the facility, defined as stationary source to determine the worst-case and other possible release scenarios. It also requires the development of standard operating procedures and other requirements.

The Emergency Response Program
The regulations require the owner or operator of a stationary source to train all employees associated with regulated substances in a process in safe procedures for operating the process and in emergency response procedures in response to abnormal conditions. This training must be documented, and the employees must be tested, to be able to demonstrate that the training has been understood. RTP is keenly aware of the potential dangers of filing an RMP that may show potential for off-site consequences that are extreme. Since the guidance of off-site consequences analysis published by USEPA is admittedly very conservative, it is often appropriate to undertake independent computer modeling to predict off-site consequences.

RTP understands that the successful preparation of a RMP for a facility requires close-working cooperation between on-site staff and the consultant. On-site engineers typically know the process much better than any consultant coming to the facility for the first time can ever hope to understand.

On-site personnel are familiar with the maintenance, training, and the organization of on-site records. RTP works with the on-site corporate staff to take maximum advantage of the experience and resources already available to you. RTP will work with you and your staff to assure the RMP for your facility is developed quickly, in compliance with the regulations, and as cost effectively as possible. RTP can also work with your in-house or consulting Public Relations group to prepare community information materials and to set up and participate in public meetings as part of the RMP process.

RTP "wrote the book" on RMP, Risk Management Planning Handbook, published by Government Institutes in March, 1998