Inspect at least 4% of the total number of RMP-regulated facilities during FY 2014. Of these inspections, at least 36% should be conducted at high-risk RMP facilities, using the list derived from established high-risk criteria and provided by headquarters to regional offices at the beginning of the fiscal year.
Regional program managers may, after consultation with and approval by headquarters, alter the population and/or hazard index thresholds for their region in order to include additional facilities on the regional high-risk list.
Conduct all RMP inspections in accordance with “Guidance for Conducting Risk Management Program Inspections Under Clean Air Act Section 112(r)” (EPA 550-K-11-001, January 2011).
See more below…
All inspections at RMP facilities with Program 2 and/or 3 processes MUST evaluate a facility’s compliance with some or all of the accident prevention and emergency
response program requirements of Subparts C, D and E of 40 CFR Part 68, in addition to evaluating compliance with other 40 CFR Part 68 requirements as time
and resources allow.
For inspections at multi-process or high-risk facilities, conduct inspections where the field portion of the inspection involves the appropriate number of inspectors/technical experts and time to evaluate the RMP program compliance and chemical safety at the facility, as stated above. For inspections at larger and more complex facilities, regions should devote additional staff and/or time as appropriate to the size and complexity of the facility.
Produce a narrative inspection report for each inspection that includes the information elements described in Appendices C and D of the inspection guidance, and include narrative findings (i.e., potential compliance deficiencies) that are supported by objective facts gained through document reviews, personnel interviews, and observations of facility and equipment status, conditions and operations.
All findings should relate directly to a specific requirement of CAA Section 112(r), 40 CFR Part 68 or an industry code or standard applicable to the subject facility. Regions may use variations of the report or checklist formats contained in the inspection guidance, provided all necessary information is present in the inspection report. Make inspection reports available to headquarters upon request.
As appropriate, evaluate facility compliance with EPCRA sections 304 and 311/312 and CERCLA section 103 during all RMP inspections. At the end of the fiscal year, report the number of high-risk facility inspections completed, as well as the total number of RMP non-filer investigations completed and of that total, the number of actual non-filers identified and required to comply with the RMP regulations.
Limit inspections that pertain exclusively to the CAA Section 112(r)(1) General Duty Clause or identifying RMP non-filers to 10% of the total number of inspections.
(EPA headquarters will re-evaluate this percentage limit on a per region basis in the event that special issues arise).
Limit inspections that pertain exclusively to the CAA Section 112(r)(1) General Duty Clause to 10% of the total number of inspections
(EPA headquarters will re-evaluate this percentage limit on a per region basis in the event that special issues arise).
Inspect RMP facilities where RMP-qualifying accidents occur during the fiscal year no later than 6 months after the accident. Accidents involving deaths, severe injuries or significant community or environmental impacts should receive the highest inspection priority.
During these inspections, regional inspectors should pay particular attention to ensure that facilities have conducted an appropriate incident investigation, prepared an investigation report, taken appropriate and timely corrective actions, and updated the facility’s risk management plan to reflect any changes resulting from the investigation and any new information required to be reported in the facility’s five-year accident history.
Here is the entire 2014 report from Office of Solid Waste and Emergency Response office of solid waste and emergency response fy 2014 national program managers guidance.pdf