CAA
Section 112(r)
Risk
Management Program: Prevention of Accidental Releases
Provisions
in section 112(r) of the Federal Clean Air Act are designed
to prevent and minimize the consequences of accidental releases
of toxic and flammable gases. Risk Management Program regulations will incorporate
the 1992 OSHA Process Safety Management requirements and will
include public risk assessment beyond plant boundaries. Specifically,
and "offsite consequence analysis" will be required and must
be disclosed to the public.
The
Risk Management Program rule differs markedly from other Clean Air Act programs
because it deals with the prevention of accidental releases
rather than ongoing emissions of air pollutants. Simulating
an accident and measuring the consequences is unlikey to be
feasible for most facilities. Therefore, computer modeling will
be required in many cases to assess the off-site consequences
of accident scenarios.
The
emphasis of the Risk Management Program is on prevention of accidental releases
and minimizing the consequences of such releases. In the event
an accident does occur, an Emergency Response Program is required
with the following elements:
- Emergency Response Equipment
- First Aid and Emergency Medical Treatment
- Training
- Drills and Exercises
- Written Plan
Risk
Management Program Elements
Hazard Assessment - to assess the potential effects of
an accidental release. This element includes the "off-site consequence
analysis" (OCA) for determining effects on neighbors.
Prevention Program - to prevent accidental releases of
regulated substances. This element generally includes safety
precautions and maintenance, monitoring, and employee safety
training.
Response
Program - to provide for specific action to be taken in
emergency situations. This element generally includes procedures
for evacuations, notifying public and local agencies responsible
for responding to accidental releases, information on emergency
health care, and employee response training measures.
How
To Get Started
Evaluate
your current program: Make sure it is up-to-date and is
being appropriately implemented. Visit the plant floor and talk
to the people who work with the process. You may find that what
is being done varies significantly from what is written.
Prepare an accidental release scenario evaluation: Make
certain the scenarios encompass a "worst case" release as defined
by the Risk Management Program rule. Choose an appropriate modeling approach. If
a scenario has previously been prepared, determine if it is
up-to-date and still makes sense.
Review emergency response procedures: Determine if your
plans are in compliance with the Risk Management Program.
Design and implement a Risk Management Program: A well designed program
should improve safety and meet the regulatory requirements as
well as pay dividends in terms of efficiency, productivity,
public relations, and profitability. |
