EPA is announcing the release of “Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)” (EPA 550-K-11-001, January 2011). This document updates and supersedes the “Guidance for Auditing Risk Management Plans/Programs under Clean Air Act Section 112(r)” of August 1999. The new document includes updated EPA policy on involvement of facility employees and employee representatives in EPA and delegated state agency on-site compliance inspections as provided for in Clean Air Act section 112(r)(6)(L).
Additionally, the guidance reflects the Agency’s focus on inspections as a means of facility oversight, and provides additional information on CAA Section 112(r) inspection procedures. The guidance preserves Risk Management Program audits as a facility oversight option. However, audits should supplement implementing agency inspection programs and not be done in lieu of inspections. EPA requests that state and local agencies that have accepted delegation of the CAA section 112(r) program adopt procedures similar to those contained in this guidance in their 40 CFR Part 68 inspection programs. EPA’s interim policy on the involvement of employees and employee representatives in CAA Section 112(r) on-site compliance evaluations established in the Agency’s April 2, 2010 memo is hereby superseded. The new guidance document, which is effective immediately, is available at http://www.epa.gov/emergencies/guidance.htm#rmp .