I recently came across some interesting RMP data from the state of North Carolina (NC), one (1) of the nine (9) states granted delegation of EPA’s authority to implement and enforce the risk management program rule. It is only a very small percentage of RMP covered facilities, but these data and trends may be the same nationwide.
In order to measure the effectiveness of the program in NC, a set of performance indicators is used to evaluate success. These indicators include measuring actions taken by industry to mitigate chemical hazards. Some of the hazard mitigation strategies include:
- substituting hazardous materials for less hazardous materials,
- minimizing quantities of hazardous materials needed,
- modifying the regulated process by minimizing pressures or temperatures, and by
- simplifying the regulated process
As the table below demonstrates, the number of subject facilities and associated processes continues to trend downward. Further analysis of the facilities no longer subject to the rule revealed that:
- 39% removed the hazardous material from their regulated process
- 16% reduced inventories of hazardous materials to below threshold quantities.