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.
Of the remaining facilities subject to the rule, the trend of hazardous materials stored on site continues to trend upward. This increasing trend in regulated substances can be mostly attributed to the increase in demand for propane.
Off-Site Consequence Analysis Trends
In order to assess the effectiveness of the program, a set of performance indicators is used to evaluate success. These indicators include measuring reductions in community vulnerabilities.
As the chart below indicates, the U.S. Census Bureau estimate that the North Carolina population has been steadily increasing over the last ten years while at the same time the reported modeled population within hazard zones has declined by approximately twenty five percent (25%) over the same timeframe.
In order to achieve reductions in hazard zones, some facilities have chosen to adopted hazard mitigation strategies. This mitigation strategy is often called “Inherently Safer Design” or “Inherently Safer Technology.” The principle of this strategy is to minimize or eliminate hazards where possible. The need to adopt inherent safety principles was highlighted in an August 2008 explosion at a chemical production plant in Institute, West Virginia.