The State of Ohio’s EPA performed “Business Impact Analysis” on their version of the Risk Management Plan, as part of an Ohio requirement. The Ohio EPA RMP rules, which are consistent with federal requirements, became effective August 13, 1999. Ohio EPA received “Delegation of Authority” for the Accidental Release Prevention Program, or Risk Management Plan (RMP) program, effective January 3, 2000. In their analysis, they provide some insight into their view of:
- what the rule intends to prevent
- how they will enforce the rule (no fines for first-time offenders)
- how much they believe it will cost employers to implement an RMP
To say the least, there are some fascinating tidbits of information in their analysis, and as they pointed out, not one person challenged their analysis in the public comment period, which I missed. I was most shocked by the statement:
A typical small business, such as a chemical retailer, with a single compound above threshold levels may be able to develop and implement a plan for a few hundred or a thousand dollars whereas a large facility with dozens or hundreds of compounds, such as a refinery, may spend $20,000-$30,000 to develop and implement a plan.
How much time did you spend in implementing your RMP?
NOTE: this information is FREE from OH-EPA. The content below, the notations, highlights, and explanations, are for SAFTENG members.