EPA's Risk Management Plan Requirements
EPA's Risk Management Plan Requirements (1994)-For the past two years, companies that own and operate ammonia refrigeration systems have been developing and implementing programs and procedures to comply with the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations. On October 20, 1993, the U.S. Environmental Protection Agency (EPA) published their long anticipated proposed regulations for Risk Management Programs for Chemical Accidental Release Prevention. On the whole, the proposed EPA requirements are very similar to the existing OSHA PSM regulations. However, the differences between the regulations are quite significant. Key differences include the need to conduct dispersion and consequence analysis and to make Risk Management Plans (RMPs) publicly available. This paper will describe the differences between the two process safety regulations, review the new EPA requirements in detail, and provide guidance on what ammonia refrigeration companies can do to prepare for EPA’s RMP requirements.
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