NEW RMP Application and Program Level flowchart
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ORFA Commentary on Ontario-related Legislation, Regulations, and Registered Refrigeration Plant Operational Best Practices
The Ontario Recreation Facilities Association Inc. (ORFA) has reviewed the Fernie, BC Ammonia Triple Fatality investigation report produced by Technical Safety British Columbia (the safety authority and governing body for pressure vessels and operating engineers in BC), and offers the following comparative as it relates to Ontario related legislation, regulations, and registered refrigeration plant operational…...
UK’s HSE Safety Alert – Catastrophic rupture of dead-leg pipe-work
Catastrophic rupture of dead-leg pipe-work Issue Date: 20.08.2019 Target Audience: Operators of Process Plant (and associated inspection bodies) which may have pipe-work dead-legs on toxic, flammable, dangerous to the environment or other critical services. Oil and gas (onshore / offshore) Chemical processing and production Nuclear Pharmaceutical Power production Key Issues: This safety alert highlights the…...
EPA RMP Program 1 five-year accident history and hazard assessment differences
Pursuant to the risk management program regulations under 40 CFR §68.10(b), Program 1 eligibility requires that the process has not had an accidental release of a regulated substance that led to off-site death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as…...
EPA RMP Worst-case “quantity released” reporting for a mixture
In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic…...
Ammonia (concentration 20% or greater) and ammonia (anhydrous) alternative release scenarios
UPDATED 9/26/22 Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous) on-site above their…...
Effect date for 2017 RMP amendments
On January 13, 2017, EPA finalized amendments (82 FR 4594) to the Accidental Release Prevention Requirements for Risk Management Programs under the Clean Air Act, Section 112(r)(7). The amendments were intended to modify:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA RMP… Emergency response Coordination activities effective date
The RMP Amendments finalized on January 13, 2017 included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not…...
What changes and amendments were made to the Risk Management Program in 2017 and when will they go into effect?
What changes and amendments were made to the Risk Management Program in 2017 and when will they go into effect?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA RMP… should the model include the entire quantity of the mixture or just the quantity of the regulated substance present in the mixture?
For the risk management program, where the concentration of the regulated flammable substance in the mixture is one percent or more by weight of the mixture, the entire weight of the mixture must be applied toward the 10,000 pound threshold quantity for the flammable substance unless the owner or operator can demonstrate that the mixture…...
EPA RMP… When does a facility need to revise its OCA?
The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA?… Membership Required You must be a member...
EPA RMP… What is considered hot work and what are the requirements related to hot work?
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to hot work?… Membership Required You...