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Due to the Montreal Protocol, the phase-out of global warming chemicals (GWC) and ozone depleting substances (ODS) has been scheduled for banning their production and use through various deadlines, from 1999 up to 2020 in North America. 

HRP has assisted facilities across the United States, Mexico, and Canada in meeting these regulatory deadlines and upgrading their facilities to appropriate design codes and standards, as well as providing appropriate safety management planning. 

With the replacement of GWCs and ODSs, the following projects may be required at your facility:

• Air Emission Discharge Permitting (EPA/State);
• Risk Management Planning (EPA);
• Process Safety Management Planning (OSHA);
• Electrical, Piping, Ventilation Upgrades (NFPA, OSHA);
• Stormwater Management Plans (EPA/State); and
• Spill Prevention Control and Countermeasure Plans (EPA).

Risk Management Plans (RMPs) were originally a compliance requirement in 1999 for facilities who maintained regulated chemicals, such as one of the 63 flammables or 97 different toxic materials above threshold values. Subsequently, follow-up audits were scheduled for five years, following initial implementation. 

The year 2004 has arrived and facilities are occupied nationwide with performing their renewal audits by the present deadline of June 21, 2004. If necessary, facilities must also update the facility Process Hazard Analyses (PHA), complete a revised Federal notification via the revised RMP Submit software, and modify Release Scenarios utilizing updated census information (Landview VI).

HRP can assist with the renewals, updates, and development of RMPs (Program 1, 2, or 3) to allow facilities the flexibility of operating in a safe environment, as well as effectively conduct manufacturing operations. HRP has successfully completed compliance reviews and prepared risk/process safety management plans for over 15 facilities in the Northeast, Southeast, and Midwest United States, and Mexico. 

One project of interest is represented in a case study for RMax's Greer, SC facility. Following successful completion, subsequent project coordination and preparation of air permits, RMP/PSMs were also conducted for RMax's Fernley, NV and Dallas, TX facilities. This demonstrated HRP's ability to complete projects on a corporate level for several facilities. 

HRP proposes to work closely with our clients in order to complete a DRAFT of the plans by at least two months prior to the startup of the regulated process. Subsequent revisions can then be made to the plan prior to placing the regulated systems into operation. Also, once the plan has been finalized, but prior to having 10,000 pounds of regulated materials on site, HRP will submit electronically only the required RMP information to EPA.

Case Study

• RMax, Inc.

Regulation

Risk Management Plan (RMP) Rule

A process at a stationary source is subject to the requirements of § 112(r) of the Clean Air Act Amendments of 1990 (EPA’s Accidental Release Prevention / Risk Management Plan Rule) if it has above a threshold quantity (TQ) of a listed toxic or flammable substance.

The RMP Rule defines three “Program Levels” based on a process’ relative potential for public impacts and the level of effort needed to prevent accidents. For each Program Level, the RMP Rule defines requirements that reflect the level of risk and effort associated with the process. The three Program Levels are briefly summarized below:

·         Program 1 – Process with no public receptors within the distance to an endpoint from a worst-case release and with no accidents with specific offsite consequences within the past 5 years.

·         Program 2 – Process not eligible for Program 1 or subject to Program 3.

·         Program 3 – Process not eligible for Program 1 and either subject to OSHA’s Process Safety Management (PSM) Standard or classified in one of the following SIC codes: 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, 2911.

Process Safety Management (PSM) Program

OSHA’s PSM requirements, according to 29 CFR 1910.119 (a)(1)(ii), are applicable to “… a process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds or more…” The PSM regulation requires employers to prepare and implement a PSM Program that includes all of the following:

1. Employee Participation
   

2. Process Safety Information:

   • Information pertaining to the hazards of the chemical

   • Information pertaining to the technology of the process

   • Information pertaining to the equipment in the process
     

3. Process hazard analysis using one or more of the following:

   • What-if

   • Checklist

   • What-if/Checklist

   • Hazard and operability study (HAZOP)

   • Failure mode and effects analysis (FEMA)

   • Fault tree analysis
     

4. Operating procedures:

   • Steps for each operating phase

   • Operating limits

   • Safety and health considerations

   • Safety systems and their functions
     

5. Training:

   • Initial training

   • Refresher training

   • Training documentation
     

6. Contractors:

   • Application

   • Employer responsibilities

   • Contract employer responsibilities
     

7. Pre-startup safety review
   

8. Mechanical integrity:

   • Written procedures to maintain the on-going integrity of the process equipment

   • Training for process maintenance activities

   • Inspection and testing

   •  Equipment deficiencies

   • Quality assurance
     

9. Hot work permits provisions
   

10. Management of change
    

11. Incident investigations
    

12. Emergency planning and response
    

13. Compliance audits
    

14.  Trade secrets

A facility must be in compliance with the requirements of both the RMP and PSM regulations prior to having more than 10,000 pounds of regulated material on site. 

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