Risk Management Program implementing

RMP lnfoTM - displays Risk Management Plans submitted by facilities under Section 112(r) of the Clean Air Act that include information about Risk Management Programs implemented to prevent and prepare for chemical accidents. 

The evaluation phase is designed to bring a systematic, disciplined approach to assessing and improving the effectiveness of risk management program implementation. It is not just the implementation that needs to be evaluated and improved it is the actual risk reduction measures thanselves. Evaluation should be conducted in a way that is commensurate with both the level of risk and the scope of the mission. 

Risk Management Program (RMP) EPA s rule requiring some facilities to prepare, submit, and implement a risk management plan. 

EPA promulgated the Accidental Release Prevention Requirements (40 CFR 68), which contain the list of regulated chemicals and requirements for facilities possessing more than a threshold quantity of a listed chemical in an individual process. Covered facilities are required to implement a risk management program and submit a risk management plan to EPA. 

Actually, before the Oklahoma City bombing, the anthrax attacks, and 9/11, OSHA and USEPA had already taken the initial steps to ensure safety and security in chemical production facilities and in other facilities that use, produce, or store listed chemicals. These steps were listed in OSHA s Process Safety Management (PSM) Standard and USEPA s Risk Management Program (RMP). Based on personal experience, having conducted VAs and modified VAs (wastewater) on both water and wastewater systems and having implemented RMP in a major U.S. wastewater system, we have to concur that these initial safety/security steps were quite effective. 

The Project Manager is responsible for the implementation of the Process Safety Management (PSM) and Risk Management Programs (RMP) and must appoint a qualified hazard study leader to conduct hazards evaluations and insure that the results are incorporated into the Process Hazards Analysis and Review. 

These common situations are discussed in the previous chapters on regulatory affairs. They can be viewed as the default set of risk management programs to be implemented in the absence of any special clinical hazard. 

At the national level within Europe, the situation becomes yet more complicated for both regulatory and less tangible, cultural reasons. Each member state has a National Competent Authority (NCA) regulating pharmaceutical product price, label and distribution. Each NCA can mandate product withdrawal within its boundaries, and notify others about its concerns. But such a decision is never binding in any other part of the EEA, and there is certainly no obligation for one member state to implement a risk management program that has been mandated at the national level elsewhere. 

The owner or operator of a stationary source shall develop a management system to oversee the implementation of the risk management program elements. 

The EPA requires, in addition, periodic audits by the implementing agency, such as the state or local air permitting agency. The frequency of such audits would be based on (1) accident history, (2) quantities of regulated substances, (3) proximity to public receptors, and (4) hazards identified in the Risk Management Program [2(220)]. 

Primary Management Systems (Chapter 2) Corporate / Management Level No formalized global risk management process Not all countries of operation have formalized safety and security programs Development of a corporate-wide transportation risk management system Implementation of corporate-wide primary management system requirements for all counties of operation... 

The first and most important step in any risk management program is to identify the hazards. Hazards analysis is the most important step in risk analysis because, unless hazards are identified, consequence and likelihood reduction cannot be implemented. In the context of process safety and operational integrity programs, this usually means that a Process Hazards Analysis (PHA) must be conducted. 

---