As part of the Clean Air Act Amendments of 1990, the Congress directed the EPA to develop a list of at least 100 substances that, if released, could cause catastrophic effects to the public. On June 20, 1996, the EPA issued its final ruling as a part of 40 CFR, Part 68. The list includes some 70 to 100 chemicals, plus substances that are flammable in quantities of 10,000 pounds or more.

This standard outlines a program with several specific components to include:

• Executive Summary
• The components of the OSHA PSM program on the covered processes
• Determination of "Worst Case and Alternative Case" scenarios
• Off-site Human Consequences Study
• Off-site Environmental Receptor
• Community ER Plans
• Risk Management Plan

Section 112® of the CAA requires the EPA to promulgate an initial list of at least 100 substances ("regulated substances") that are known to cause, or may be reasonably anticipated to cause death, injury, or serious adverse effects to human health or the environment if accidentally released. The EPA is required to set threshold quantities for each of the listed substances. The list and threshold quantities promulgated in the federal register on January 31, 1994 are, with the exception of methyl chloride, equal to or higher than OSHA's list.

Our staff of individual hygienists, professional engineers and safety engineers is ready to assist you in meeting the requirements of the Risk Management Program.

Please call our office at 1-888-287-4655 or e-mail us for a cursory survey at no fee.

 
Program 1 requirements apply to processes for which a worst-case release, as evaluated in the hazard assessment, would not affect the public. These are sources or processes that have not had an accidental release that caused serious offsite consequences. Remotely located sources and processes using listed flammables are primarily those eligible for this program.

Program 2 requirements apply to less complex operations that do not involve chemical processing (e.g. retailers, propane users, non-chemical manufacturers and other processes not regulated under OSHA's PSM Standard.

Program 3 requirements apply to higher risk, complex chemical processing operations and to processes already subject to the OSHA PSM. According to the category in which a process is categorized, the owner/operator is required to develop an Executive Summary, conduct studies regarding Worst Case and Alternative Case Scenarios, Blast Wave or Radiant Heat Modeling Calculations, Human offsite consequence analysis, Environmental Receptor determinations and submission of a Risk Management Plan. Also, Emergency Response Plans must be developed.

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