Risk Management Plan
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Agricultural establishments that store, handle, or use certain toxic or flammable chemicals above threshold amounts must develop and implement a program to prevent accidental releases of those chemicals.
The examples below illustrate common chemicals and thresholds used in ag operations that will subject you to EPA's Risk Management Program requirements:
- Chlorine in quantities greater than 2,500 pounds. Chlorine is commonly used in agriculture for washing fruits, vegetables, and other harvested products and for disinfection.
- Ammonia in quantities greater than 10,000 pounds for anhydrous or 20,000 pounds for aqueous. Ammonia is often used in agriculture for food refrigeration systems. Note: Ammonia used as an agricultural nutrient when held by farmers is exempt from the requirements, as long as it is used on that establishment. It would NOT be exempt if resold or used on another establishment. Farm cooperatives and groups of farmers who buy, use, and sell ammonia are NOT exempt.
- Flammable fuels (including propane, butane, ethane, methane, and others) in quantities greater than 10,000 pounds originally triggered the Risk Management Program requirements. The Chemical Safety Information, Site Security and Fuels Regulatory Relief Act, however, removed flammable substances used as fuel or sold as fuel at a retail facility from coverage under the Risk Management Program. Flammable substances, such as propane, butane, ethane, methane and others, used onsite as fuels are excluded from the Risk Management Program requirements. Flammable substances held for sale as fuel at retail facilities are also excluded. Flammable substances used for non-fuel purposes or held for sale by non-retail facilities are NOT excluded. If you are not sure whether a flammable substance is covered, contact EPA's RMP Hotline at 1-800-424-9346 or 703-412-9810.
These examples do not cover all the circumstances that may require you to comply with the Risk Management Program. Be sure to check Appendix A: 40 CFR 68 (PDF) (55 pp, 516K) for a list of chemicals covered by the law, and then consult Chapter 1: General Applicability from EPA's General Guidance for Risk Management Programs to determine how the requirements apply to your establishment.
- EPA Supports myRMP
- Important Information for 2004
- Your Risk Management Program
- Submitting a Written Plan
- General Clean Air Act Requirements
- Help From EPA
EPA notified The Fertilizer Institute (TFI) of its support for the Web-based myRMP program, developed cooperatively by TFI and the Asmark Institute designed to assist agricultural retailers conduct required updates to risk management plans. EPA is recommending that retailers nationwide use myRMP. The program was launched Aug. 13, 2007 and is available for use by retailers across the country.
Important Information for 2004
New amendments to the Risk Management Plan (RMP) program were published in the Federal Register on April 9, 2004. For information on the five year update requirement, amendments to the rule, and information on how to submit your RMP, please consult the RMP Information page.
Your Risk Management Program
As a farmer, you may be using hazardous chemicals that pose a risk to the surrounding community should an accident occur. The Risk Management Program rule requires businesses that hold greater than a threshold quantity of a regulated substance to implement a "risk management program," a regular program of activities designed to prevent an accidental chemical release and mitigate any releases that may occur.
Many of the baseline requirements of this rule -- such as evaluating the dangers associated with your operations and determining how to make them safer -- are activities that conscientious businesses already undertake using established industry codes and standards (such as NFPA-58), so you may already be in compliance with parts of this new regulation.
To fully comply, you will need to implement a risk management program for the chemicals of concern on your establishment, and submit a summary report called the Risk Management Plan (RMP) to EPA. How much you will need to do in your program will depend upon the level of risk that your operations pose to nearby communities, and whether or not you have a history of significant accidental releases.
Submitting a Written Plan
A written summary of your program -- called a "Risk Management Plan (RMP) " -- must be submitted to EPA by the date on which a threshold quantity of a regulated substance is present in a process at your facility. To determine if you need to implement a Risk Management Program and submit a Risk Management Plan, consult Chapter 1: General Applicability from EPA's General Guidance for Risk Management Programs. Risk Management Plans will be made available to state and local officials involved in planning for and responding to chemical emergencies, and to the public (the sections of the Risk Management Plan containing "Offsite Consequence Analysis" information are available to the public only in Federal reading rooms). In this way, police, firefighters, and the people who live and work near your establishment can be assured that you are taking steps to prevent accidents involving chemicals that could cause a risk to the community.
General Clean Air Act Requirements
Even if you determine that you do not have a process that requires a formal risk management program, remember that you still must adhere to the "general duty clause" of the Clean Air Act [Section 112(r)(1)]. This clause, which went into effect in 1990, makes the owners and operators of facilities that have extremely hazardous substances responsible for ensuring that the chemicals are managed safely.
The statute says that owners and operators have a general duty to identify the possible hazards of the chemicals at their facility, do what is necessary to prevent the releases of those chemicals, and take steps that will limit the harmful effects of any accidental releases. Facilities can make sure they are working towards fulfilling their General Duty Clause obligations by:
- adopting or following relevant industry codes or standards
- being aware of accidents or incidents in their industry sector and what they reveal about potential hazards
- understanding unique circumstances of their facility which may require a tailored program of planning and prevention
- for further information please see the General Duty Clause fact sheet (PDF) (3 pp, 64K)
Help From EPA
For additional information on the Risk Management Program listed chemicals and Risk Management Plan (RMP) requirements, you can:
- Call EPA's RMP Hotline at 1-800-424-9346 or 703-412-9810
The Hotline has technical staff who can provide you with up-to-date information and help answer your questions about the Risk Management Program.
- Go to the Risk
Management Program Overview
This site provides access to information about the Risk Management Program, including guidance documents, support for submitting Risk Management Plans, and questions and answers about the Risk Management Program Rule. Many documents can be downloaded from this site.
- Get free publications/software from NSCEP
The National Service Center for Environmental Publications can supply most of EPA's Risk Management Program materials. NSCEP will send you one free copy of up to five document/software titles in any 2-week period. You can request documents/software by title or document number (see partial list of RMP materials and their document numbers below).
-- Call in requests to 1-800-490-9198
-- Fax requests to 1-513-489-8695
-- Request online from NSCEP
- Guidance documents and publications available
EPA and several key industry associations have developed guidance to help facilities comply with the Risk Management Program. Call the RMP hotline or visit the RMP Web site for a comprehensive list.
EPA's General Risk Management Program Guidance. When no industry-specific guidance has been developed for a sector, this document helps a facility to develop risk management programs and plans. EPA Document Number: EPA 550-B-00-008.
Guidance for Conducting Risk Management Program Inspections Under Clean Air Act Section 112(r) (PDF) (84 pp, 498K). EPA Document Number: EPA 550-K-11-001.
RMP*Comp Modeling Program for Risk Management Plans
RMP*Comp is the most widely used software for completing the offsite consequences analysis (OCA), including both worst case scenarios and alternative scenarios required under the Risk Management Plan Rule. It is free and very easy to use.
RMP*eSubmit Software and Manual
On March 13, 2009, EPA provided new software called RMP*eSubmit for facilities to use for online RMP reporting. EPA asks that all facilities use this new method to submit RMPs because it is easy to use, will improve data quality, and will enable you to access your RMP 24 hours a day, 7 days a week.
Text of applicable laws and regulations
Clean Air Act [Section 112(r)(1)]
Environmental regulations that cover chemical accident prevention (40 CFR Part 68)
Chemical Safety Information, Site Security, and Fuels Regulatory Relief Act (PDF) (8 pp, 173K)
More information from EPA
Local Emergency Planning Committee (LEPC) Database
Q&A's on ammonia used as an agricultural nutrient
Related publications from the Ag Center
Risk Management Plan (RMP) Information