The Environmental
Protection Agency (EPA) issued the Risk Management Assessment
Rule, which is authorized in Section 112(r) of the Clean Air Act. This
rule required manufacturing sites and warehouses that store or use in a
process a specified amount of hazardous substance(s) to submit a Risk
Management Plan by June 21, 1999. Traditionally, the regulations
concerning hazardous substance(s) have been focused on clean up and
response to accidents. The Risk Management Plan is an emergency plan that
focuses on the worst-case scenarios for hazmat release, and was
developed to insure the prevention of accidents.
Risk
Management Plans are
considered a "hot topic" in the chemical industry. For many companies,
the development of the plan will be cost and labor intensive.
Consultants tend to charge high rates for plans that comply with new
regulations. Due to the fact that there is a
high demand for the service, and because knowledge of the new regulation is limited,
the research costs are often transferred to the client.
The
plan is labor intensive because
a facility must revise the RMP whenever a new substance or process
is added. This revision requirement is difficult for facilities with
frequent inventory changes. Although the EPA is considering methods to
make the plan more
flexible for the facilities, the plan is still cumbersome and requires
expert knowledge.
RCS,
Inc. prides itself on being on
the forefront of regulations. President J. Anthony Garrido, P.E.A.,
P.H.M.,
assisted Dr. Lyse Helsing of the EPA in the implementation of the model
Risk Management Plan protocol. Mr. Garrido has first-hand knowledge of
the plan and the EPA's expectations. Members of RCS, Inc.'s staff have
been
performing research on the topic since 1993 and have developed
databases
to reduce the complications associated with record-keeping and calculations. RCS, Inc.'s goal is to provide
Risk Management Plans for
RCS, Inc.'s clients that not only comply with the regulations, but are
cost-effective as well.
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