Risk Management Planning (RMP)
RTP understands the intricacies associated with successful preparation and implementation of RMP at a facility. In fact, RTP wrote the book on RMP, Risk Management Planning Handbook, published by Government Institutes in March, 1998, second edition Summer, 2002. RTP understands that the successful preparation of a RMP for a facility requires close-working cooperation between on-site staff and the consultant. On-site engineers typically know the process much better than any consultant coming to the facility for the first time. On-site personnel are also familiar with the maintenance, training and the organization of on-site records.
RTP works with the on-site staff to take maximum advantage of the experience and resources already available. RTP then works with the facility management to assure the RMP is developed quickly, in compliance with the regulations, and is cost effective . RTP can also work with your in-house or consulting Public Relations group to prepare community information materials and to set up and participate in public meetings as part of the RMP process.
Risk management programs include plans to detect and prevent or minimize the accidental release of regulated substances as stipulated in Section 112(r) of the Clean Air Act. In terms of applicability, all users of hazardous chemicals are required to plan for accidents as required by the general duty clause. The RMP for a specific site is a document which includes three basic elements:
- The Hazard Assessment;
- The Prevention Program; and
- The Emergency Response Program.
The Hazard Assessment
The final RMP regulations require a Hazard Assessment which includes an evaluation of the potential range of releases for a facility, including worst-case accidental releases, and the analysis of potential off-site consequences. It also requires documentation of an applicable facility’s five-year Accident History.
The Prevention Program
The Prevention Program has a strong link to the Hazard Assessment, as process and incident reviews often provide insight into potential events that could have onsite or offsite consequences. One element of the Prevention Program is a formal required analysis known as the Process Hazard Analysis (PHA). The PHA utilizes recognized methodologies such as Hazard and Operability Studies (HAZOP) or What-If/Checklist Studies to review all processes which contain more than a threshold quantity of regulated substances at the facility (the list of substances and quantities vary between RMP & PSM) and identify potential means for catastrophic failure and release. Evaluation of potential offsite impacts can often begin with release scenarios identified in the PHA process.
During Prevention Program activities, the facility must determine the applicable Program level (1, 2 or 3). Many facilities are covered under OSHA’s Process Safety Management (PSM) Standard. Once a program is determined, the facility must develop standard operating procedures and other requirements.
The Emergency Response Program
The Emergency Response Program will be based on computer modeling of hypothetical releases to calculate threat zones within which employees or offsite populations might need to evacuate or stay sheltered in the event of an emergency release. The hypothetical release scenarios are based on the Hazard Assessment.