Identification of Industrial Buildings, Commercial Buildings, and Recreational Areas

Pursuant to the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator is required to conduct an offsite consequence analysis and analyze a worst-case release scenario and alternative release scenarios as part of a risk management plan (RMP). When completing these scenarios, public receptors need to be identified. A public receptor means offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result of an accidental release (§68.3). What are considered industrial buildings, commercial buildings, or recreational areas, and how can they be identified?

Industrial and commercial  buildings include buildings used for industrial manufacturing, production, service, sales, business or other industrial or commercial activities. Recreational areas include  land that is designed, constructed designated, or used for recreational activities. Examples are national, state, county, or city parts, other outdoor recreational areas such as golf courses or swimming pools and bodies of water (oceans, lakes, rivers, and streams) when used by the public for fishing, swimming, or boating. Public and private areas that are predictably used for hunting, fishing, bird watching, bike riding, hiking, or camping or other recreational use also would be considered recreational areas..  Most of these institutions or areas can be identified from local street maps.

While roads and parking lots are generally not considered public receptors, a public road or parking lot where the public gathers, such as for street fairs, parades, and races, is considered a public receptor. Public receptors also include areas of a stationary source where the public may gather, including but not limited to an onsite park available to the public, parking lots used as carnival sites, or on-site picnic areas for public use. It is up to the owner or operator to account for such uses as public receptors.

It should be noted that the RMP only needs to identify which types of public receptors are within the circle defined by the endpoint for the worst-case and alternative release scenarios; the institutions and areas do not need to be listed out individually.

Additional information can be found in Chapters 2 and 4 of the General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR Part 68) (EPA550-B-04-001), available at the following URL:

https://www.epa.gov/rmp/guidance-facilities-risk-management-programs-rmp