• Regulatory Applicability and Exemption Analysis
• RMP Program Development
• RMP Program Implementation
• Enforcement Representation and Regulatory Negotiation
In June of 1996 and in accordance with the Clean Air Act Amendments of 1990, EPA issued the “Risk Management Program for Chemical Accidental Release Prevention” (RMP) rule for the same list of 137 toxic, reactive, flammable, or explosive chemicals issued by OSHA. The purpose of the RMP is to protect workers and the public from the effects of an accidental release of highly hazardous chemicals. Like the OSHA PSM standard, the EPA RMP rule program is applicable to Facilities that store a listed chemical above the Threshold Quantity (TQ) assigned by EPA. Unlike the OSHA PSM Standard, the EPA RMP includes three program Levels (1, 2 and 3) which is determined by the results of a hazard assessment, release history, and coordination with the Local Emergency Planning Commission and First Responder. The RMP Accident Prevention Elements applicable to Program Levels 1, 2, and 3 include:
RME Safety and Environmental, LLC (RME) has been providing RMP services to its customers since 1998. RME has developed a Risk Management Program Template for RMP Program Levels 1, 2, and 3 that can be adopted as is, or modified to meet the Corporate-specific Policies. The RME RMP is designed for easy reference and to facilitate external and internal compliance audits. The RME RMP program has been subjected to hundreds of EPA and OSHA compliance audits in EPA Regions 4, 5, 6, 7, 8, 9 and 10 since 1998.
RME provides RMP services to a variety of clients and industries in more than 30 states across the U.S. RME services are tailored to the Client needs and include program development through implementation, or customized to specific accident prevention elements, including:
Regulatory Applicability and Exemption Analysis
Site Inspection and Data Collection
EPA RMP Registration (Preparer)
Process Design and Construction Management
Hazard Assessment
Process Safety Information Development
Written Operating Procedures
Code relevant Hazard Review and Process Hazard Analysis with Risk Analysis
Training
Maintenance or Mechanical Integrity Programs Meeting Relevant Industry and Code Standards
Management of Change Implementation
Pre-Startup Review Post Construction or Major Modification
Compliance Audits -3rd Party or Representation During Agency Audits
Incident Investigations
Contractor Management
Emergency Planning, Coordination, and Response Exercises