Overall Risk Management Program

The EPA has very specific guidance to the owner or operator for the performance of offsite consequence of accidental releases of substances regulated 

A final element of the hazard assessment is compiling and documenting a five-year history of releases of the regulated substances. EPA s RMP requires the facility to document the releases that caused, or had the potential to cause, offsite consequences. The accident history must include  

Note that most of the releases that meet the criteria of the EPA RMP are already reported under CERCLA and SARA Title III. Most of the information needed to define accidental release scenarios will be derived from the process hazard analysis. 

As clarification of SARA Title III and CERCLA relationships, the following is provided. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) is designed to help clean up inactive hazardous waste sites. It also requires industries to disclose to their communities what hazardous substances they use and store. CERCLA authorized EPA to remediate polluted sites and created the Superfund to pay for site cleanups when there is no clear-cut responsible party. EPA can pursue potentially responsible parties to make them pay for response and remediation activities. Section 313 of the Emergency Planning Community Right-to-Know Act of 1986 (SARA Title III) requires EPA to establish an inventory of routine toxic 

The integrated approach of the EPA prevention program consists of the following nine elements. These elements adopt and build on the OSHA PSM program elements  

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Figure 8.1 shows how the Management System, Technical Information, Emergency Response and Performance Monitoring all feed into, and are also modified by, the overall Risk Management program. 

Promote a positive organizational culture that is conscious of its safety, health, environmental, and security responsibilities by communicating these responsibilities to all stakeholders and by training all stakeholders as part of the organization s overall risk management program. 

Special regulatory provisions. European Economic Area (EEA). The components of risk management programs in Europe have been similar to those listed above. However, it is probably fair to say that, overall, there has been less experience with these programs in Europe than in the United States. 

The risk management coordinator runs the risk management program on a day-to-day basis. He or she assists the subcommittees and reports to management on overall progress. Responsibilities for this person include ... 

Risk Management Analysis. Evaluate program data to establish risk-based priority ranking for all program sites, measure overall risk reduction... 

The development of some of the risk information shown in Table 5.2, such as consequences and likelihood, is discussed in the next chapter. The table also has a Follow-Up section— the management of which is often under the control of the PSM coordinator or someone who is charged with managing the facility s overall risk program. 

The steering committee provides overall direction to the risk management and PSM programs. The committee should be chaired by the facility manager and is responsible for the overall implementation of risk management at the site. Typically, the steering committee will be composed of the following persons ... 

By way of an overview introduction, the chapter will provide an overall summary of the RMP, discuss the hazard analysis requirements to include consequence analysis, describe the prevention program requirements and the emergency response requirements, and finally discuss the risk management plan. 

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