Developing a Risk Management Program for a Flexible Polyurethane Foam Manufacturing Facility
The U. S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) regulations, require facilities to develop a formal Risk Management Program (RMProgram) and to register and submit a Risk Management Plan (RMPlan). Regulated facilities must implement a RMProgram and submit a RMPlan before 21 June 1999. The RMP regulations will require most Flexible Polyurethane Foam (FPF) manufacturing facilities to register and submit an RMPlan because they use or store toluene diisocyanate (TDI) in quantities that exceed the threshold quantities specified in the RMP regulations.
In developing the RMProgram many FPF manufacturers will encounter difficult business decisions due to the lack of complete and timely guidance from EPA, the unique properties of TDI, and the methods used to handle TDI at the FPF manufacturing facilities. This paper discusses the issues associated with developing a RMProgram for a FPF manufacturing facility. The paper is based on the experience obtained while developing a RMP guideline document for TDI for the Polyurethane Foam Manufacturing Association (PFA)1. The RMP regulations require an offsite consequence analysis be conducted for the worst-case release of the regulated chemical(s). This analysis may be conducted using dispersion modeling techniques or EPA look-up tables. Actual dispersion modeling results for an example FPF manufacturing facility are presented in this paper and a comparison between the results using the EPA look-up tables and the ALOHA dispersion model are discussed.
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