Ten Tips to Prepare for EPA Risk Management Program Inspections
This was prepared to assist anhydrous ammonia retailers that handle, process or store anhydrous ammonia above a threshold quantity of 10,000 pounds that are subject to chemical safety requirements within the Clean Air Act Risk Management Program.
Have copies of:
- Your most recent risk management plan submittal (should be within the last five years).
- The most recent material safety data sheet from your anhydrous ammonia suppliers.
- The hazard review. (Does it include all of the hazards relating to your facility?)
- Your compliance audits, which are required every three years.
- Your written operating procedures.
- Incident investigations for any accident, especially if it resulted in injury or off-site evacuation/shelter in place.
Be able to show you have:
- Coordinated your accident prevention efforts with local first responders.
- Performed equipment maintenance and inspections.
- Trained employees and provide refresher training.
- Demonstrated compliance with current ANSI K61.1/CGA G-2.1 industry standard.
You want to be certain that you have implemented the new industry standards, planned them, or documented that they are not needed. Inspectors will look at vehicle barriers, emergency shutoffs, emergency breakaways at risers, proper paint (to avoid excessive rust), hoses/relief valves that are not out of date, warning labels, and emergency water sources.
For guidance: please review myRMP, which was developed by The Fertilizer Institute and reviewed by EPA. myRMP is available at www.asmark.org/myrmp/ .
For additional information, contact George Hess, EPA Environmental Scientist, at 913.551.7540 or firstname.lastname@example.org.