The EPA published Risk Management Program (RMP) regulations in the 1990s requiring facilities storing hazardous substances above threshold quantities to submit Risk Management Plans. The EPA proposed new RMP provisions in 2016 in response to chemical incidents, including requiring facilities to improve public access to chemical hazard information and conduct emergency response exercises. Facilities with higher risk processes would need to conduct root cause analyses, compliance audits, and coordinate emergency response. If finalized, facilities would have one to four years to comply with new emergency response and accident prevention requirements.

1. EPA’S RISK MANAGEMENT PROGRAM –
NOW AND THE FUTURE
The EPA published its Risk Management Program (RMP)
regulations in the 1990s. Facilities with regulated substances
stored above threshold quantities (TQ) within a process are
required to implement an RMP and submit a Risk Management
Plan (report) to EPA. The RMP regulation establishes three
“program levels” for regulated processes:
• Program 1 (P1) - Processes do not affect the public in case
of worst-case scenario and no accidents with off-site
consequences in past five years.
• P2 – Processes not eligible for P1 or P3.
• P3 - Processes not eligible for P1 that belong to one of
several industrial classification codes or are subject to
OSHA’s Process Safety Management (PSM) standard.
EPA has proposed new RMP provisions in response to recent
catastrophic chemical release incidents in accordance with the
following schedule:
• March 14, 2016 – EPA proposed new RMP provisions.
• Effective date – still pending.
• Within one-year of effective date – comply with emergency
response coordination requirements.
• Within four-years of effective date – comply with remaining
requirements.
If promulgated, the rules require all facilities to improve public
accessibility of chemical hazard information. For facilities with
P2 or P3 processes, the proposed rules include added accident
prevention program and emergency response requirements.
INCREASED PUBLIC AWARENESS
The proposed RMP regulations would require that basic RMP
information be made available to the public; for example on the
company web site. Facilities would also be required to hold a
public meeting for the local community within 30 days of an
RMP reportable accident. In addition, upon a request by a local
agency, the facility must supply information on RMP-related
emergency response exercises, compliance audits, accident
history, investigative reports, and Inherently Safer Technologies
that have been implemented by the facility.
FIELD AND TABLETOP EXERCISES
Responding facilities with an RMP-reportable accident will have
to conduct a full field exercise within a year of an accident.
Facilities subject to the emergency response program
requirements of subpart E of the rule (or ‘‘responding facilities’’)
will also need to conduct a full field exercise once every five
years and one tabletop exercise annually in the other years. A
facility will have one year from the rule effective date to comply
with these new requirements.
NEW REGULATIONS FOR P2 AND P3
PROCESSES
• Conduct a root cause analysis as part of an incident
investigation of a (near) catastrophic release.
• Contract with a 3rd
-party for a compliance audit after a
reportable release or significant noncompliance in
implementing requirements.
• Coordinate with local emergency response agencies, at
least yearly, to ensure resources are available to respond to
a release.*
• Make annual notifications to ensure emergency contacts
are accurate.*
• Facilities in NAICS codes 322 (paper), 324 (petroleum and
coal), and 325 (chemical) must conduct a Safer Technology
and Alternative Analysis and evaluate the feasibility of
Inherently Safer Technologies
*AS EPA HAS PROPOSED, THE FACILITY WILL HAVE ONE YEAR
FROM THE RULE EFFECTIVE DATE TO COMPLY WITH THESE
REQUIREMENTS.

2. REPRESENTATIVE RMP PROJECTS
City of Dubuque, Dubuque, IA
Water & Wastewater Treatment Plant RMP
City of Fairfield, Fairfield, IA
Master Plan and Risk Management Plan
City of Fort Madison, Fort Madison, IA
Water Treatment Plant RMP
City of Mason City, Mason City, IA
Wastewater Treatment Plant RMP
Confidential Industrial Client, IA
Food Product Facility Off-site Consequence Analysis Update
Confidential Industrial Client, IA
Food Product Facility RMP assistance
Confidential Industrial Client, IA
Corn Milling Facility RMP assistance
Confidential Industrial Client, IA
Grain Processing Facility RMP Plan
Confidential Industrial Client, IA
Drug & Pharmaceutical Facility RMP Program Review & Update
Confidential Industrial Client, WI
Drug & Pharmaceutical Facility RMP Off-site Consequence
Analysis & Hazard and Operability Study
Confidential Industrial Client, IA
Industrial Machinery Facility Risk Management Plan
East Kentucky Power Cooperative, Maysville, KY
RMP/Process Safety Management Study
Sethness Products, Clinton, IA
RMP/PSM Assistance
CONTACT INFORMATION
Corporate Office
225 Iowa Avenue
Muscatine, IA 52761
Phone: 563.264.6600
Toll Free: 800.878.6806
Fax: 563.264.6658
www.stanleyconsultants.com
Local Office
2658 Crosspark Road Suite 100
Coralville, IA 52241
Phone: 319.626.5342
Fax: 319.626.3993
Contact:
Patrick Ryan, Ph.D.
Senior Environmental Scientist
Phone: 319.626.5342
RyanPatrick@stanleygroup.com
BACKGROUND
Established in 1913
Total Staff: 1,000
Member (employee)-owned
corporation
DOMESTIC OFFICE
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