At least every five (5) years a Risk Management Plan must be updated. We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update. I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from this new rule and how it should be reflected in our RMP Update(s).
Section 9, Emergency Response section of a facility’s RMP asks about other Emergency Response regulations the facility may be subjected to and then proceeds to offer up some examples, such as:
- OSHA Regulations at 29 CFR 1910.38
- OSHA Regulations at 29 CFR 1910.120
- Clean Water Act Regulations at 40 CFR 112
- RCRA Regulations at 40 CFR 264, 265, 279.52
- OPA-90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, 30 CFR 254
- State EPCRA Rules of Laws
But if you read my article from this weekend, Have we updated our EAP and/or ERP to ensure compliance with 40 CFR Part 1604?, you know all about the new CSB Release Reporting Rule. Here are more posts on the topic:
Thisnew reporting rule is in EFFECT and we should be including it on line 9.8.g which says:
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g. Other. Specify any other emergency response regulations or laws to which your facility is subject. |
An RMP facility would certainly be subject to 40 CFR 1604 – Accidental Release Reporting.