RMP SERIES

RMPs Are on the Way!

How LEPCs and Other Local

Agencies Can Include Information

from Risk Management Plans in

Their Ongoing Work

United States

Environmental Protection

Agency

Office of Solid Waste

and Emergency Response

(5104)

EPA 550-B99-003

November 1999

www.epa.gov/ceppo/

Chemical Emergency Preparedness and Prevention Office Printed on recycled paper

ABOUT THIS BOOKLET...

The Emergency Planning and Community Right-to-Know Act of 1986

(EPCRA) calls for the establishment of local emergency planning

committees (LEPCs). LEPCs are to have broad-based membership whose

primary work is to receive information from local facilities about chemicals in the community, use that information to develop a comprehensive

emergency plan for the community, and respond to public inquiries about

local chemical hazards and releases. There are now more than 3,500

LEPCs, and they reflect the diversity of our country. Most LEPCs are organized to serve a county; some are for a single large city; others cover the

better part of an entire state. 

We are publishing this booklet in anticipation of the impact a new regulation will have on LEPCs. The regulation implementing section 112(r) of

the Clean Air Act requires facilities to develop a risk management program to prevent and mitigate the effects of chemical accidents, and to

document the program in a Risk Management Plan (RMP). These RMPs

will be available to state and local agencies and to the public. Therefore,

LEPCs will have access to more detailed information about chemical hazards in their communities. LEPCs can use this information to improve

emergency response plans, inform the public about chemical accident

hazards and risks, and work with industry and the public to reduce risks

and improve chemical safety.

This booklet will not teach you everything about the RMP regulation.

Rather, the purpose of this booklet is to describe how LEPCs and similar

local agencies can take advantage of the risk management program to

build on their existing planning and right-to-know activities under EPCRA.

We intend this booklet to follow the style of and replace It's Not Over in

October, a document that EPA and other groups published in 1988 to

encourage new LEPCs not to stop working once they had completed their

emergency plans by the October 1988 deadline. For more detailed information about the RMP regulation, consult EPA's General Guidance for Risk

Management Programs (http://www.epa.gov/ceppo).

The RMP regulation contains a deadline for industry: June 21, 1999. By

that date, covered facilities were required to have in place a risk management program and must have submitted an RMP to EPA. This deadline for

industry is an opportunity for LEPCs. June 1999 can be a beginning, a

time to update existing emergency plans with the new RMP information, a

time to better understand chemical hazards in your community and share

your understanding with the public, a time to declare in word and deed

that you will promote chemical safety in your community by focusing on

preventing accidents.

RMPs are on the way! We hope that this booklet helps you and your LEPC

in your important work of protecting human life and the environment

where you live.

WHAT'S INSIDE?

New Information Is Becoming Available

about Chemicals in Your Community . . . . . . . . . . .1

Information You Already Have . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

New Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

Information Sources and Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

A Role for Everyone in Chemical Safety . . . . . .3

What Is the RMP Regulation? . . . . . . . . . . . . . . . . . . . . . . .5

What Chemicals Are Covered? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

What Facilities Are Covered? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

What Must a Facility Do? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Hazard Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Management System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Prevention Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Emergency Response Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Different Requirements for Different Kinds of Facilities . . . . . . . . . . . . . . . .9

RMPs Are Coming! . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

What Information Is in an RMP? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Offsite Consequence Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Five-Year Accident History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Prevention Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Emergency Response Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Confidential Business Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

How Can LEPCs Access RMPs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

More on Offsite Consequence Analysis . . . . . . .14

LEPCs Coordinate Chemical Safety

Activities in the Community . . . . . . . . . . . . . . . . . . . . . . . .17

Get Everyone Involved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Enhancing LEPC-Industry Relations; Encouraging Compliance . . . . . . . . .18

Release Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Working with Small Businesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

Response Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

Industry Outreach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

New Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Talk with Neighboring Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21
RMPs Are on the Way!

Risk Communication: LEPCs Are a Bridge

between the Public and Local Industry . . . . . .22

Basic Rules of Risk Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Hazards Versus Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Three Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

A Special Case: Dealing with Worst-Case Scenarios . . . . . . . . . . . . . . . . . . .26

Respond to Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27

Improving Your Emergency Plans . . . . . . . . . . . . . . .28

Working with Industry to Prevent 

Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29

A Few More Suggestions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Funding Your Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Liability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Handy Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32

Appendices and Attachments

Appendix A: Checklist – Ideas for Action

Appendix B: EPA Regional Office Contacts for EPCRA and RMP Programs

Appendix C: Some Background Information: Comparison of Green Book

and RMP Offsite Consequence Analysis (OCA) Guidance

Methodology

Appendix D: Regulated Substances: Chemicals Covered by the RMP

Regulation and Their Threshold Quantities

Y2K Alert

Customer Satisfaction Survey: RMPs Are on the Way! 
page 1

NEW INFORMATION IS BECOMING

AVAILABLE ABOUT CHEMICALS IN

YOUR COMMUNITY

In 1990, section 112(r) was added to the Clean Air Act (CAA).

Section 112(r) calls on EPA to establish requirements for facilities to

reduce the likelihood and severity of accidental chemical releases,

using hazard assessments, prevention programs, and emergency

response planning. EPA implemented section 112(r) in its Risk

Management Program regulation. Facilities that are covered by the

Risk Management Program will summarize their program activities

in Risk Management Plans (RMPs). Facilities were required to submit their RMPs to EPA by June 21, 1999, and EPA has made the RMPs

available to the public. A host of new information is now available

to you!

The provisions for accidental release prevention in CAA section

112(r) and the Risk Management Program regulation build on the

planning and preparedness foundation laid by the Emergency

Planning and Community Right-to-Know Act of 1986 (EPCRA—also

known as SARA Title III). EPCRA is intended to encourage emergency planning efforts at state and local levels and to increase public awareness and understanding of potential chemical hazards present in the community. EPCRA sets up a framework for emergency

planning at the state and local levels and provides the authority to

collect chemical information that is important to communities. The

CAA section 112(r) program provides a complementary approach to

chemical safety—it requires that facilities take steps to identify

and control on-site hazards. It also provides for public access to

information about the actions facilities are taking to prevent and

mitigate the potential offsite effects of these hazards.

Information You Already Have

Under EPCRA, you currently receive information from covered facilities on the chemicals they have, the quantities of chemicals stored,

the hazards associated with those chemicals, and information on

storage locations and conditions. Specifically, the EPCRA program

provides you with the following information:

• Notification from facilities that have extremely hazardous substances (EHSs) in excess of threshold planning quantity

amounts. This information is reported directly to the local

emergency planning committee (LEPC). (EPCRA sections 302

and 303)

CAA section 112(r) is entitled Prevention of Accidental

Releases. This booklet

speaks about the Risk

Management Program rule

(40 CFR part 68) that EPA

published to implement section 112(r). The rule established the requirements of

the Risk Management

Program.

Another term you will want

to become familiar with is

"Risk Management Plan,"

which refers to the document

a facility must prepare to

summarize its risk management program. In this booklet, we use "RMP" to refer

to the Risk Management

Plan.
RMPs Are on the Way!

page 2

• Notification of emergency information about accidental releases of reportable quantities of EHSs and substances regulated

under CERCLA (CERCLA hazardous substances). This information is reported to the LEPC's community emergency coordinator. (EPCRA section 304)

• Material Safety Data Sheets (MSDSs) – or lists of hazardous

chemicals – from facilities that have threshold quantities of

hazardous chemicals and that must have an MSDS under the

Occupational Safety and Health Act, and annual inventory

information on the quantity, hazard category, and location and

storage conditions of hazardous chemicals at facilities at

threshold levels. This information is reported directly to the

LEPC. (EPCRA sections 311 and 312)

• Annual reports on total yearly releases of toxic chemicals from

regulated facilities. This information is reported to EPA. EPA

compiles this information in a database called the Toxics

Release Inventory (TRI) and makes the information available to

the public. (EPCRA section 313)

New Information

Under the CAA section 112(r) Risk Management Program, additional

information is now available to you – in the RMPs that facilities

submitted to EPA. 

• Facility hazard assessments, including worst-case release and

alternative release scenarios;

• Facility accident prevention activities, such as use of special

safety equipment, employee safety training programs, and

process hazards analyses conducted by the facility;

• Past chemical accidents at a facility; and

• Facility emergency response programs and plans.

Both EPCRA and the CAA section 112(r) Risk Management Program

encourage communication between facilities and the surrounding

communities about chemical safety and chemical risks. Regulatory

requirements, by themselves, will not guarantee safety from chemical accidents. Information about hazards in a community will allow

local emergency officials and the public to work with industry to

prevent accidents. 
page 3

For example, facilities are required to provide information about

possible worst-case scenarios under the Risk Management Program

– and officials and the public can use the information to understand the chemical hazards in the community and then engage in a

dialogue with industry to reduce risk. In this way, accident prevention is focused primarily at the local level where the risk is found.

Information Sources and Contacts

Q: Where can I get updates on the latest EPCRA and RMP guidance

and program information?

A: EPA's Chemical Emergency Preparedness and Prevention

Internet Homepage at http://www.epa.gov/ceppo/ 

Q: Where can I order copies of documents?

A: National Service Center for Environmental Publications (NSCEP)

Toll-Free: (800) 490-9198

Q: Where can I get answers to my questions and order single

copies of documents?

A: The RCRA, Superfund and EPCRA Hotline

Toll-Free: (800) 424-9346

TDD: (800) 553-7672

DC Area: (703) 412-9810

Fax: (202) 651-2061

Monday-Friday, 9:00 a.m. - 6:00 p.m. EST

A ROLE FOR EVERYONE IN CHEMICAL

SAFETY 

Industry complies with EPCRA and RMP reporting requirements

and participates actively with LEPCs and State Emergency

Response Commissions (SERCs) to ensure that the public understands chemical hazards in the community and that community

responders are prepared to take appropriate steps if an accident

happens. In addition to the reporting requirements, the RMP regulation requires facilities to develop a risk management program to

ensure that the facility has implemented accident prevention and

emergency response programs that fit the chemical hazards at the

facility. In addition to these specific requirements, CAA section

112(r)(1) establishes a general duty for industry to operate safely. 

EPA's federal role is to provide national leadership, guidance, and

technical assistance for implementing both EPCRA and the RMP regTips &

Hints

By combining RMP information with EPCRA data, your

LEPC can enhance its role as

a key player on issues that

relate to the use of hazardous chemicals in the community. You can:

(1) Use accidental release

scenarios to set realistic priorities among your local

emergency preparedness

activities.

(2) Serve as a resource for

facilities and the public in

promoting risk communication.

(3) Use accident histories

and summaries of prevention

activities to help you talk

with facilities about steps to

reduce risk.

(4) Provide compliance assistance to facilities on emergency response, accidental

release scenarios, and other

issues.

(5) Reach out to other community groups (for example,

the local zoning board, environmental groups) who may

be interested in elements of

the RMP and help them

understand the data and how

the data could assist them.
RMPs Are on the Way!

page 4

ulation; provide access to TRI data about chemical releases (under

EPCRA section 313); and receive risk management plans from industry and then make them available to state and local agencies and

the general public. Additionally, EPA Regional offices will implement all or part of the risk management program in states that have

chosen not to seek formal delegation from EPA to implement the

RMP program.

The states, through the SERCs, provide EPCRA leadership to ensure

that an emergency planning and EPCRA implementation structure is

developed and to provide training and technical assistance to communities. Under the Clean Air Act, state (as well as local and

regional) air permitting agencies issue permits to some facilities

that are also covered by the RMP regulation. In addition, EPA will

delegate to interested states and local agencies the authority to

implement the RMP program – this is already happening in

Georgia, Florida, North Carolina, South Carolina, New Jersey,

California, Puerto Rico, and the Virgin Islands. Some SERCs are

involved in implementing the RMP program.

At the local level, LEPCs carry out the emergency planning and

community right-to-know requirements of EPCRA. First responders

(who are typically represented on LEPCs) implement contingency

plans when response to a chemical accident is necessary. LEPCs

will increasingly be a source of information about chemical risks in

the community, as information under the RMP regulation becomes

available to the public.

Did you

know?

According to EPA's

Emergency Response

Notification System (ERNS),

more than 402,000 accidents

involving hazardous chemicals were reported in the

United States in the 12 years

from 1987 to 1998. These

accidents resulted in nearly

4,000 deaths, 25,300

injuries, and 1,400 evacuations affecting 147,000 individuals. Eighty percent of

these reported accidents

occurred at industrial and

commercial facilities.

CAA Section 112(r) Implementing Agencies

Agencies charged with implementing the RMP regulation will

conduct outreach, technical assistance, training, reviews of

RMPs, audits of RMPs, and inspection of risk management programs at facilities. In its Guidance for Implementing Agencies

(see table of resources for how to obtain a copy), EPA notes that

each state and locality will have its own approach to encouraging chemical safety. EPA will work with each interested state

and/or local agency to develop an appropriate RMP implementation program. 

To learn which agency is implementing the RMP regulation in

your area, you can call your EPA Regional Office (see contact

list at the back of this booklet), or visit the CEPPO website at

http://www.epa.gov/ceppo. 
page 5

A major role for LEPCs is to work with industry and the interested public to encourage continuous attention to chemical

safety, risk reduction, and accident prevention by each local

stakeholder.

The public can get involved by increasing its awareness and

understanding of chemical hazards and supporting actions to

ensure public safety and protection of the environment.

WHAT IS THE RMP REGULATION?

The RMP regulation (40 CFR part 68) is designed to prevent accidental releases to the air of substances that may cause immediate,

serious harm to public health and the environment and to mitigate

the effects of releases that do occur. The regulation is available

from EPA. Call the RCRA, Superfund and EPCRA Hotline at (800)

424-9346 or visit EPA’s website at http://www.epa.gov/ceppo .

What Chemicals Are Covered? 

The RMP regulation applies to processes at facilities that have more

than a threshold quantity of any of 77 acutely toxic substances,

such as chlorine and ammonia, and 63 highly volatile flammable

substances, including propane. These substances are called “regulated substances” in this booklet to distinguish them from chemicals on other lists.

A new law excludes regulated flammable substances from the RMP

program when those substances are used as fuel or held for sale as

a fuel at a retail facility. The law defines retail facility as a facility at

which more than one-half of the income is obtained from direct

sales to end users or at which more than one-half of the fuel sold,

by volume, is sold through a cylinder exchange program. The main

effect of this provision is to exempt from RMP coverage all facilities

that had previously been covered solely because they used flammable substances, particularly propane, for fuel (e.g., for heating,

drying, etc.), and to exempt most propane distribution facilities.

Propane distribution facilities that do not meet the criteria for

“retail facility” are still covered by the RMP rule. Facilities such as

oil refineries that manufacture listed flammable substances are still

covered, as are facilities that use listed flammable substances for

non-fuel purposes (e.g., as a chemical feedstock).

Most of the acutely toxic regulated substances are also extremely

hazardous substances (EHSs) under EPCRA section 302. The flammable regulated substances are all subject to reporting under

A facility (called a "stationary source" in the regulation) is covered by the RMP

regulation if:

(1) It has a regulated substance...

(2) ...over the threshold

quantity...

(3) ...in a process.

Take Note
RMPs Are on the Way!

page 6

EPCRA sections 311 and 312. Each toxic regulated substance is

assigned a threshold quantity under the RMP regulation that is

generally higher than the threshold planning quantity for the same

substance under EPCRA. All flammable regulated substances have

a threshold quantity of 10,000 pounds under the RMP regulation,

the same as the threshold for these substances under EPCRA sections 311 and 312. The list of RMP regulated substances and thresholds is provided at the back of this booklet.

The RMP thresholds are applied to individual “processes” at a regulated facility, while EPCRA thresholds are applied to the site as a

whole. A process, as defined by the RMP regulation, means any

activity involving a regulated substance, including any use, storage,

manufacturing, handling, or on-site movement of such substances,

or combination of these activities. Any group of vessels that are

interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release, is considered a single process. Consequently, there may be some facilities in

your community that report under EPCRA for a specific substance

and might appear to meet the threshold quantity under the RMP

regulation as well, but in fact are not subject to the RMP rule

because they do not have a threshold quantity in a single process.

Tips &

Hints

EPCRA section 312 reports

will provide you with a list

of local facilities potentially

subject to the RMP regulation. However, remember

that the EPCRA thresholds

apply to the facility as a

whole, rather than to an

individual process, and thus

the list of EPCRA facilities

may include facilities not

covered by the RMP regulation. In addition, the RMP

thresholds for toxics are generally higher than the

EPCRA thresholds.

• Manufacturers of inorganic chemicals and industrial gases

• Manufacturers of plastics,

resins, and organic chemicals

• Manufacturers of agricultural chemicals

• Petroleum refineries and

gas processing plants

• Metal and equipment

manufacturers

• Food businesses with

large ammonia refrigeration systems

• Propane retailers and distributors 

• Pulp and paper mills

• Larger industrial facilities

and institutions that store

propane for use as fuel

• Agricultural retailers who

sell ammonia fertilizer

• Larger water treatment

and wastewater treatment

systems

• Refrigerated warehouses,

warehouses that handle

chemicals, and chemical

distributors

• Electric companies

• Large U.S. military and

Department of Energy

installations

Examples of specific operations that may be regulated

under the RMP rule:
page 7

What Facilities Are Covered?

EPA has estimated that thousands of facilities are potentially subject to the regulation, including manufacturers, warehouses, retail

businesses, and public facilities. The rule does not apply to transportation, including pipelines. Regulated substances present in

gasoline, when in distribution or related storage for use as fuel for

internal combustion engines, also are not covered. In addition, the

rule provides an exemption for the use of ammonia by farmers as a

fertilizer (although not for those businesses that produce or sell

ammonia to those farmers).

What Must a Facility Do? 

There are five main elements of facility compliance with the RMP

regulation:

(1) A hazard assessment;

(2) A management system;

(3) A prevention program;

(4) An emergency response program; and

(5) A Risk Management Plan (RMP) that describes these activities.

The first four elements are described here. The Risk Management

Plan is described in more detail in the next chapter.

Hazard Assessment

The hazard assessment consists of two components:

(a) A five-year history of serious accidents involving the regulated

substances. Every covered facility must provide detailed information on any serious accident that occurred in the previous

five years and had specific impacts either on the site or in the

surrounding community.

(b) Descriptions of one or more potential accidental release scenarios involving the regulated substances. Every facility must

analyze the potential offsite consequences of a worst-case (catastrophic) release. 

EPA has defined the parameters of a worst-case scenario (such as

atmospheric conditions, endpoints, and release criteria) for this

analysis. In addition, if the worst-case scenario could impact the

public, one or more alternative releases that are more likely to
RMPs Are on the Way!

page 8

occur must be examined. (Some of these special terms are

explained in the section of this booklet called “More on Offsite

Consequence Analysis.”)

For each release scenario, the facility must estimate the greatest

distance from the facility to a point beyond which no serious acute

effects are anticipated. The facility must also identify the populations and environments potentially affected.

Management System

Every facility that has a worst-case analysis showing potential offsite impacts is required to develop a management system to oversee the implementation of the Risk Management Program elements.

The management system provision also requires the facility to designate a qualified person or position with overall responsibility for

the development and implementation of the risk management program elements and to document the names of people or positions

and define lines of authority.

Prevention Program

The main objective of the Risk Management Program regulation is

to prevent accidents from occurring, and this is done by ensuring

that every covered facility implements a chemical accident prevention program. To do this, the facility must understand its hazards

and integrate safety into all aspects of its processes and business.

The facility must make safety a way of life so that the risk from

chemical accidents to employees and the public is minimal. The

prevention program must be implemented on a daily basis if it is to

achieve its goal—no chemical accidents.

The prevention program is intended to formalize a series of management practices for identifying hazards and managing the risk of

a chemical accident. A good prevention program focuses on hazard

analysis, process controls, operating procedures, employee training,

and maintenance activities. Not all facilities are required to develop a prevention program. A facility with only Program 1 processes

(see box on next page) is not subject to prevention program

requirements and will provide no data on its prevention activities.

Emergency Response Program

At a minimum, every facility subject to the regulation must coordinate its response activities with the LEPC for its area or with local

responders. 

Tips &

Hints

The RMP regulation requires

every facility subject to the

regulation to coordinate its

response activities with the

LEPC for its area or with

local responders. This is an

opportunity for you to:

• Ensure that you have in

place a clear and quick

method to notify neighbors

when an accident happens

• Ensure that all call-down

lists are consistent

• Coordinate operating procedures among community

first responders and facility

employees

• Review equipment lists to

ensure you have the right

equipment and that you

know where it is when an

accident happens

• Practice evacuation and

shelter-in-place procedures

with neighbors
page 9

In addition, if a facility will use its own employees to respond to

releases (for example, with a facility hazmat team), the facility must

implement a full emergency response program that includes a plan,

training, and plan review and updates. The facility may choose to

develop one plan following National Response Team guidance

(available at http://www.epa.gov/ceppo) as described on page 19.

The facility must coordinate its plan with its LEPC plan. 

Different Requirements for Different Kinds of

Facilities 

Facility risk management programs will vary. The RMP regulation

requires facilities to develop a program that reflects the different

levels of risk and complexity that different processes pose. A

process falls into one of three categories—Program 1, Program 2, or

Program 3—based on accident history, worst-case scenario results,

and industrial sector. In general, Program 1 processes are less complex, pose less risk to the public, and have had no accidents with

offsite consequences. Program 2 and 3 processes are more complex

and have worst-case scenarios that would impact the public. The

compliance requirements for Program 1 processes are less stringent

than are the requirements for Program 2 and 3 processes, which are

also more formal.

Facilities May Have Processes Subject to Different Risk

Management Requirements Based on the Different

Risks They Present

Program 1 Processes

No accidental releases resulting in offsite impacts within

five years of RMP submittal

No public receptors in worst-case scenario zone and

Emergency response procedures coordinated with local

emergency organizations

Program 2 Processes

Not eligible for Program 1 or subject to Program 3

Program 3 Processes

Not eligible for Program 1 and

Subject to OSHA process safety management standard 

or in NAICS code 32211, 32411, 32511, 325181, 325188, 

325192, 325199, 325211, 325311, or 32532
RMPs Are on the Way!

page 10

RMPS ARE COMING!

The Risk Management Plan describes the activities that each facility

is conducting to comply with the regulation, its “risk management

program.” Initial RMPs were submitted to EPA by June 21, 1999. The

information in the RMP will be updated every five years or sooner

under certain circumstances, including major changes to the facility

or its covered processes. In addition, facilities will keep additional

supporting documentation on their risk management program on

site. 

What Information Is in an RMP?

An RMP consists of an executive summary in text form as well as

answers to a series of questions focusing on individual elements of

the risk management program. The latter information is reported

as data, such as names, dates, multiple choice selections, and “yes”

or “no” answers. 

Each RMP will contain information on the identity of the facility, its

offsite consequence analysis, five-year accident history, prevention

program, and emergency response program.

The RMP is not like a contingency plan—even though we call it a

“plan.” The RMP is primarily a series of data fields with numbers,

words and phrases, and yes/no answers to specific questions. You

can use information in the data fields to understand steps the facility is taking to prevent or respond to a possible accident; for example,

there will be information about employee safety training, inspections by non-facility personnel, equipment maintenance, and management oversight.

Executive Summary

The executive summary in the RMP is your introduction to the facility. This section includes a brief description of the facility, its primary operations and processes, and the regulated substance(s)

handled. The executive summary also reviews the release scenarios from the offsite consequence analysis; general and chemicalspecific release prevention activities; the five-year accident history;

the emergency response program; relevant facility response and

prevention policies; and any planned changes to improve safety. 

Registration

The registration section in the RMP provides information about the

facility (e.g., street address and emergency contacts) and the

processes in which regulated substances are found. The facilityTips &

Hints

• The executive summary

can be used by the community as a background piece for

events involving the facility,

such as developing exercises

and contingency plans. In

the Kanawha Valley in West

Virginia and in Augusta,

Georgia, the executive summaries have been used as a

tool to provide information to

the public.

• NAICS codes are a new

industrial classification system that is replacing the

Standard Industrial Codes

(SIC).

• LEPCs can compare the

new RMP registration information with existing EPCRA

data about the facility. This

is an opportunity to update

"Facility" data in CAMEO.

• For alternative release scenarios, the facility can

choose modeling parameters

(e.g., typical weather and

atmospheric stability information) that fit the local situation.
page 11

specific data include points of contact for emergencies and risk

management program questions as well as standard address information.

For each covered process, the registration section lists the regulated

substances (and quantities) in the process, the program level of the

process, and the North American Industry Classification System

(NAICS) code for the process. The NAICS code identifies what the

process does (for example, water treatment or metal plating).

These data will help you identify specific operations at a facility or

compare them with similar operations elsewhere.

Offsite Consequence Analysis

Facilities with any Program 1 processes must include at least one

worst-case release scenario in their RMPs. Facilities with Program 2

or Program 3 processes must include in their RMPs information

about both worst-case release and alternative release scenarios.

The number of scenarios depends in part on the type and number

of regulated substances in covered processes. EPA has defined

many of the release modeling parameters for the scenarios,

although some facility-specific data (for example, certain weather

conditions) can be used.

In the RMP, facilities report the modeling parameters and dispersion model(s) that they used to do their offsite consequence analyses. You can use this information to “re-create” a facility’s results,

using CAMEO and ALOHA, EPA’s Offsite Consequence Analysis

Guidance, or RMP*Comp (available at http://www.epa.gov/ceppo).

For each release scenario, facilities report in the RMP the distance

beyond which no serious, acute effects are anticipated; the residential population within that distance (in all directions from the point

of release); and which categories of public receptors (for example,

schools, residences, hospitals, commercial/industrial areas) or environmental receptors (national/state parks, wildlife sanctuaries, and

federal wilderness areas) are located within that distance. Facilities

may choose to submit a graphic file to illustrate each scenario on a

local map.

Five-Year Accident History

The accident history that facilities report in their RMPs provides

information on each accidental release from a regulated process

that resulted in specific on-site or offsite impacts during the preceding five years, in greater detail than the EPCRA section 304

reports that you have received in the past. Releases from non-covTips &

Hints

• As you review the data

about potential offsite consequences that facilities report

in their RMPs, keep in mind

that air modeling uncertainties are significant and different models are likely to

produce different results.

(For more information,

including explanations of

some of the special terms

used when discussing offsite

consequence analysis, see

"More on Offsite

Consequence Analysis" on

page 13.)

• Workers at the facility and

local residents may consult

the accident history information as they try to understand previously unexplained

odors and gas clouds coming

from the facility. However,

such events will only be

included in the accident history if they meet the RMP

rule's criteria for reporting

an accident.

• LEPCs may want to compare the prevention program

information for a local facility with that of a similar

facility in the community, the

state or even the nation.

The LEPC might be able to

work with facilities (privately, or through discussion at

open meetings) to introduce

safety practices that are

effective at another facility.
RMPs Are on the Way!

page 12

ered processes, even if they involved regulated substances, or

releases of non-listed substances from covered processes, are not

included. 

For each accidental release reported in the accident history section

of the RMP, facilities report standard descriptive information, as

well as some new information such as the weather conditions, onsite and known offsite impacts, the initiating event and contributing

factors, whether offsite responders were notified, and any changes

made at the facility as a result of the accident. 

Prevention Program

In the RMP, facilities report prevention program information separately for each covered process. This section of the RMP identifies

the major hazards for the process; the relevant process controls,

mitigation systems, and detection and monitoring systems; and any

changes made to the process since the last hazard evaluation. This

section also provides dates indicating when specific prevention

activities (for example, updates of procedures) were last conducted. This information provides a basis for comparing similar operations at different facilities.

Facilities must retain a substantial amount of supporting documentation to comply with program requirements of the RMP regulation.

While facilities are required to make this documentation available

to EPA or the state implementing agency, they are not required to

make it available to the public. If certain items are of interest to you

or to members of the public, you may want to talk to facilities about

making this information available. Much prevention program documentation will relate to internal tracking or standard work records,

but there will also be hazard review or PHA (process hazards analysis) recommendations, compliance audit reports, and accident

investigation reports. EPA is encouraging facilities to make as much

of this information as possible (or some form of summary) available to the public if requested. Because the RMP regulations

expand the information collection authority granted to LEPCs under

EPCRA section 303(d)(3) to apply to facilities with flammable regulated substances, the LEPC can get any of this information that is

necessary to develop an emergency plan.

Emergency Response Program

The RMP does not provide detailed information on the facility

emergency response program. There is a series of yes/no questions indicating whether the facility has a response program and
page 13

also some dates indicating when specific activities (for example,

drills or exercises, plan review) were last conducted. Facilities that

have chosen to develop their own response capability will keep an

emergency response plan and procedures on site. As noted above,

the LEPC can request this information from all facilities subject to

CAA section 112(r) in developing an emergency plan.

Confidential Business Information

Facilities can claim some RMP data as confidential business information (CBI). An LEPC interested in obtaining data claimed CBI may

request that EPA determine whether the claim is valid. If EPA determines that the information is not CBI, and after EPA has notified the

facility claiming CBI, the information may be released. If EPA determines that the information is CBI, an LEPC may nonetheless be able

to obtain the information under 40 CFR 2.301(h)(3), which provides

for sharing of CBI with state and local governmental agencies having responsibilities under the CAA or its implementing regulations.

However, LEPCs can gain access to CBI data under this rule only if

they can protect its confidentiality.

Under EPCRA section 303(d)(3), LEPCs may compel an EPCRA section 302 facility to provide any information necessary to enable the

LEPC to develop and implement an emergency plan. An EPCRA section 302 facility must comply with such LEPC requests for information even if the facility has made a valid CBI claim under the RMP

regulation.

How Can LEPCs Access RMPs?

EPA has placed RMPs, except for the offsite consequence analysis

information, on the Internet in a format that allows the public to

search them and download any that are of interest. This database,

called RMP*Info, is located with other EPA data in Envirofacts on

the Internet at http://www.epa.gov/enviro. 

To simplify access by state and local governments, EPA will set up

separate databases containing the full RMPs for all of the facilities

in each state. Additionally, EPA will provide software, called

RMP*Review, for use by implementing agencies, LEPCs, and others

to manage their databases. Please contact your EPA Regional Office

CEPP contact for details (see Appendix B).
RMPs Are on the Way!

page 14

MORE ON OFFSITE CONSEQUENCE

ANALYSIS

Not all LEPC members may have an extensive technical background,

but you will want to (1) understand how a facility derives its worstcase and alternative release scenarios and (2) be familiar with the

underlying terminology. The following are answers to some of

EPA’s most frequently asked questions.

Q: What Is Meant by a Worst-case Release Scenario?

EPA has defined a worst-case release as the release of the

largest quantity of a regulated substance from a single vessel or

process line that results in the greatest distance from the point

of release to a specified endpoint. 

EPA requires that the worst-case release scenario incorporate

certain parameters related to the chemical released, conditions

of the release, atmospheric conditions, and health effects of

concern (“toxic or flammable endpoints”). Facilities use these

parameters to estimate the distance away from the location of a

release beyond which no serious, acute effects are anticipated.

These parameters are discussed in more detail below.

Q: What Is Meant by an Alternative Release Scenario?

The RMP regulation requires Program 2 and 3 facilities to project potential releases of regulated substances that are more

likely to occur than worst-case scenarios and to predict the consequences of such releases. These are called alternative

release scenarios. The RMP regulation provides information

that facilities must use for such predictions as part of doing the

offsite consequence analysis required for the risk management

program at the facility.

Q: What Is a Toxic Endpoint?

A toxic endpoint is the endpoint for a regulated toxic substance.

For a particular regulated substance, it is the concentration of

that substance in air below which it is believed that most people could be exposed for up to one hour without serious health

effects. EPA has determined toxic endpoints for each of the

regulated toxic substances. The toxic endpoints are listed in

the RMP regulation.

Q: What Is a Flammable Endpoint?

A flammable endpoint is the endpoint for a regulated flammable substance. How it is measured depends on the type of

release considered. For example, the flammable endpoint for a

Worst-Case Modeling

Parameters 

Toxic endpoints: as specified in the regulation for

each regulated toxic substance 

Flammable endpoints: 1 psi

for all flammable substances

Wind speed: 1.5 meters/sec

(unless the facility can prove

this has not occurred in the

last 3 years)

Stability class: F (unless

facilities can prove this has

not occurred in the last 3

years)

Ambient temperature: highest daily maximum temperature in past three years

Humidity: average humidity

for the site

Height of release: ground

level 

Surface roughness: urban or

rural

Gas density: model must

account for whether or not

gases are heavier than air

Temperature of substance:

highest daily maximum for

past three years or process

temperature, whichever is

higher (for liquids only)
page 15

vapor cloud explosion is based on the pressure from the resulting blast wave. The flammable endpoints to use for different

types of releases are provided in the RMP regulation.

Q: What Is a Stability Class?

Pasquill stability classes (ranging from “A” to “F”) are meteorological categories of atmospheric conditions. Pasquill stability

class A represents unstable conditions under which there are

strong sunlight, clear skies, and high levels of turbulence in the

atmosphere, conditions that promote rapid mixing and dispersal of airborne contaminants. At the other extreme, class F represents light, steady winds, fairly clear nighttime skies, and low

levels of turbulence. Airborne contaminants mix and disperse

far more slowly with air under these conditions, and may travel

further downwind at hazardous concentrations than in other

cases. Stability class D, midway between A and F, is used for

neutral conditions, applicable to heavy overcast, daytime or

nighttime.

Q: What Is the Distance that Facilities Must Estimate for Their

Release Scenarios?

Facilities must estimate the distance from the location of a

release to the endpoint that could result from the accidental

release of a regulated substance. They must estimate this distance for each release scenario in their RMP. To understand

what populations could be at risk from an accidental release,

the facility is to draw a circle with the facility at the center. The

radius of the circle is the distance to the endpoint.

Q: How Is The Distance to an Endpoint Estimated?

Facilities estimate the distance to an endpoint by first estimating the amount of a regulated substance that would be released

in an incident (either a worst-case release scenario or an alternative release scenario), and then using air dispersion modeling techniques (or a tool that incorporates such techniques) to

estimate the distance to an endpoint for that amount of the regulated substance. Note that the distances that facilities report

in their RMPs are estimates. EPA has guidance documents

(Offsite Consequence Analysis Guidance as well as industryspecific guidance for developing RMPs) and software

(RMP*Comp) to help facilities estimate the distances. Facilities

may use EPA’s guidance or any other air dispersion modeling

techniques provided that the techniques meet certain conditions as outlined in the RMP regulation.

What about the Approach in

the "Green Book"?

EPA, DOT, and FEMA published Technical Guidance for

Hazards Analysis (commonly

known as the Green Book) in

1987. Many LEPCs have

been using the Green Book to

estimate vulnerable zones for

chemicals in the community.

The release modeling done

for the RMPs will be based

on parameters similar to

those in the Green Book, but

with some differences. (For

example, the RMP regulation

specifies parameters not

used in the Green Book

approach. Also, in recent

years toxicologists have

refined the toxic endpoints

for some chemicals.) EPA

encourages LEPCs to use the

Offsite Consequence Analysis

Guidance approach to modeling releases for any subsequent planning, so the

results reported by industry

in their RMPs will be comparable to those the LEPC calculates.

Appendix C of this booklet is

a detailed comparison of the

Green Book methodology and

the methodology in EPA's

Offsite Consequence Analysis

Guidance.
RMPs Are on the Way!

page 16

Q: What Is Meant by Air Dispersion Modeling Techniques?

Air dispersion modeling techniques are mathematical models

that are used to estimate the distance that a released substance

would travel from the location of the release to the endpoint,

given the amount of the substance released and certain conditions of the release. The estimated distance will vary depending on the air dispersion model used.

Q: How Certain Is The Distance to The Endpoint?

For a given scenario, people can use different release models

and obtain predictions of the distance to an endpoint that may

vary significantly. Even using the same model, different input

assumptions can cause wide variations in the predictions.

LEPCs need to recognize that the predicted distances lie within

a considerable band of uncertainty and communicate this fact

to the public when they discuss the scenario results.

Differences in models may explain why two facilities handling

the same covered substances in the same amounts may have

come up with different results. (Of course, differences in prevention programs may also account for different results, particularly in the case of alternative release scenarios.) EPA’s

approaches are generally intended to produce conservative

results—they are more likely to overestimate distances. For

other models, you may want to ask the facility for an assessment of where its distance prediction lies within the plausible

range of uncertainties.

Q: If There Is an Accident, Will Everyone Within the Distance to the

Endpoint Be Hurt? 

In general, no. For an explosion, however, everyone within the

circle would certainly feel the blast wave because it would

move in all directions at once. However, while some people

within the circle could be hurt, it is unlikely that everyone

would be. But releases usually do not lead to explosions. A fire

is more likely than an explosion, and fires are usually concentrated at the facility.

For toxic chemicals, the released chemicals would usually move

in the direction of the wind. Only people in a small fraction of

the circle would be exposed if a release occurred. Whether

someone is hurt depends on many factors, such as whether the

chemical is dispersed by the wind, or if the release is stopped

quickly.

Generally, it is the people who are closest to the facility who

face the greatest danger. Although it is not impossible for peo-
page 17

ple beyond the distance to the endpoint to be hurt, it is much

less likely. However, the risk should not be dismissed. The

RMP regulation assumes that a worst-case release involves the

failure of the single largest vessel containing a regulated substance at the facility. It is conceivable, although highly unlikely,

that more than one vessel could fail at the same time, resulting

in a larger release than the worst-case scenario predicts. In

such a case, people beyond the distance to endpoint could be

affected.

Q: How Likely Are the Worst-case and Alternative Release

Scenarios?

It is generally not possible to provide accurate numerical estimates of how likely it is that these scenarios will actually happen. Quantifying risk for accident scenarios is rarely feasible

because there are few data related to rates for equipment failure and human error.

In general, the risk of a worst-case scenario occurring is low.

Although catastrophic vessel failures have occurred, they are

rare events. Combining them with worst-case weather conditions (as required by the RMP regulation) makes the overall

scenario even less likely. This does not mean that such events

cannot or will not happen, but they are very unlikely to happen.

For the alternative scenario, the likelihood of the release is

greater and will depend, in part, on the scenario chosen.

LEPCS COORDINATE CHEMICAL SAFETY

ACTIVITIES IN THE COMMUNITY

Get Everyone Involved

LEPCs should have broad-based membership that includes, at a

minimum, representatives of elected officials, law enforcement,

emergency management, fire service, emergency medical services,

healthcare professionals, local environmental and transportation

groups, hospitals, the media, community groups, and owners and

operators of the facilities covered under EPCRA.

Wide-ranging community involvement will increase the credibility

of the LEPC plan and improve community cooperation in an emergency. Both EPCRA and the RMP regulation assume that citizens

want chemical safety in the community. Including concerned citizens on the LEPC and inviting them to your meetings will promote

communication between industry and the public, foster understanding of chemical hazards, and help quell rumors.

Tips &

Hints

Ideas for LEPC Effectiveness

Have you tried to revitalize

your membership recently?

In some cases, a new SERC

chair or a new LEPC chair is

able to recruit new members

for the LEPC.

As with every committee,

one or two active new members can energize the entire

LEPC.

Have a clear agenda. Start

(and end!) your meetings on

time.

If you have subcommittees,

check with them a few weeks

before the full LEPC meets.

Be sure that the subcommittees do their work in

advance.
RMPs Are on the Way!

page 18

Enhancing LEPC-Industry Relations;

Encouraging Compliance

Since EPCRA passed in 1986, a rule of thumb is that effective LEPCs

include active and committed industry representatives. Industry

representatives bring expert understanding of chemicals and chemical processes. Numerous facilities have provided financial and

other support to make LEPCs successful.

The RMP regulation provides specific opportunities for you to work

more closely with the facilities in your community on risk communication, accident prevention and risk reduction, and compliance

assistance. (See the later sections for discussions of risk communication and accident prevention.) As you work with facilities

through these and other issues, you may become the organization

they turn to when they need to understand community concerns

and help in providing constructive answers to questions from the

public. In helping them, you can work to ensure that they address

community issues related to chemical safety quickly and accurately,

which will, in turn, make your LEPC the group on which the community relies.

Depending on the skills of your membership, the LEPC may be able

to serve as a local source of RMP compliance assistance. Although

you may not want to become involved with more technical issues,

almost all of the RMP program elements are well-suited to your

involvement.

Release Modeling

EPA has provided free copies of CAMEO (a software program that

helps LEPCs manage and interpret information about a facility and

its chemical inventory) to more than 2,000 LEPCs. Using ALOHA

and LandView (a software program that provides Census Bureau

data and helps users map facilities and nearby populations), LEPCs

can now assist facilities in conducting the offsite consequence

analysis required by the RMP regulation. Small businesses will

appreciate help in collecting and entering their release modeling

data and identifying public and environmental receptors that could

be impacted by a release. LEPCs can then incorporate this updated

facility information into the community plan.

Users should be aware, however, that ALOHA has some limitations

which may make it unsuitable for RMP offsite consequence analysis

modeling in certain situations. For example, ALOHA does not have

the capability to model the offsite consequences of flammable substance releases, and for toxic substances, ALOHA only provides

endpoint distances out to a maximum of 6 miles from the source
page 19

(large releases of certain chemicals, such as chlorine, will exceed

this distance under worst-case conditions). If you desire to conduct

RMP OCA modeling in these and other situations for which ALOHA

is unsuitable, you should use a different model. 

One such model is RMP*Comp. RMP*Comp is a software program

designed by EPA and the National Oceanic and Atmospheric

Administration (NOAA) specifically for the purpose of conducting

RMP OCA modeling. It follows the methods and techniques

described in EPA's RMP Offsite Consequence Analysis Guidance.

RMP*Comp is capable of providing OCA modeling results for all 140

RMP regulated substances and provides endpoint distances out to a

maximum of 25 miles. RMP*Comp is available for free—you can

download it from the Internet (http://www.epa.gov/ceppo) or order

a copy from the National Service Center for Environmental

Publications (NSCEP) at 1-800-490-9198.

Working with Small Businesses

Local planning and response officials can help small businesses

sort out facility-specific preparedness issues, identify response

resources, and formalize their emergency response program. The

RMP regulation also may serve as an incentive for facilities to adopt

the “One Plan” approach and formalize incident command issues.

This provides a perfect opportunity to discuss mutual aid agreements and joint training and exercise programs.

Response Coordination

Facilities that do not have their own response team must coordinate

with the LEPC concerning listed toxic chemicals, and with the fire

department about listed flammable chemicals. Local fire officials,

in conjunction with the building inspector, can work with facilities

to improve fire prevention practices, including compliance with

NFPA standards or other fire and related codes.

Industry Outreach

LEPC industry representatives can provide other facilities with

technical assistance or contacts for further information on a variety

of prevention program issues. Assistance could include explaining

issues related to the OSHA Process Safety Management (PSM)

Standard (a regulation requiring certain facilities to implement accident prevention activities similar to those described on page 8) or

help in collecting and understanding safety information, industry

safety standards, or approaches to employee training and equipment maintenance.

Tips &

Hints

In June 1996, EPA and the

other National Response

Team (NRT) agencies published integrated contingency

planning ("One-Plan") guidance. The NRT encourages

facilities to develop one plan

to comply with all federal

contingency planning

requirements (rather than

develop separate plans for

each regulation). EPA, the

Coast Guard, the Office of

Pipeline Safety at the U.S.

Department of Transportation, OSHA, and the Minerals

Management Service

promised to accept the oneplan format whenever a

facility must submit a contingency plan to them for

review and approval. To

obtain copies of the one-plan

guidance, contact EPA’s

Hotline at (800) 424-9346.
RMPs Are on the Way!

page 20

New Partnerships

The availability of RMP information also provides LEPCs with an

opportunity to develop new partnerships with other organizations

in the community. People and groups may need to be reminded

that you have available much specific information about chemicals

in your community. Although they may not be interested in the

entire RMP, medical professionals, the news media, planning/zoning officials, and researchers will likely find specific sections of the

RMPs from local facilities of particular interest. Working with them

will further extend the reach of the LEPC into the community, creating a stronger constituency for the LEPC that enables you to take

advantage of a wider base of skills and experience.

Medical professionals (including emergency medical technicians,

doctors in private practice, health clinics, and hospitals) will appreciate information on potential acute health hazards as well as the

recommended treatment for exposures. Distributing a list of nearby

facilities and their regulated substances can assist in the first step; if

the medical professionals are interested, you can request a copy of

the emergency response plan and then selectively send out the first

aid and emergency medical treatment information. At the same

time, keep in mind that clinics and hospitals will want to know if

they are potentially vulnerable to an air release.

The news media can play an effective role in risk communication.

If you do not already have regular representation from local newspapers and radio and television stations on your LEPC, this is a

great time to get them involved. Now that the RMPs are available,

you are in a position to work with the news media to spread the

risk reduction message in your community. 

You might consider producing press packets to help the local news

media understand and use RMP information. At the same time, you

can describe the other related activities of the LEPC and get additional exposure for efforts such as commodity flow studies and

field exercises.

You may have multiple audiences within the news media. While

news reporters with an interest in environmental, public safety, and

health issues will likely find RMP information intriguing, broadcast

meteorologists may actually be the best people for discussing the

dispersion of air releases with the public. 

The accidental release scenarios in the offsite consequence analysis will provide local planning and zoning officials with more

information when they address development issues. Being aware
page 21

that a new school, hospital, residential area, or shopping center

could be directly affected by a facility using an acutely toxic or

highly flammable substance can only improve the decision-making

process. 

Engineering and environmental professionals, and researchers

at local colleges and universities, are likely to find RMP information

of even greater interest than EPCRA and other environmental data.

If there are specific operations or types of facilities of significant

concern to the community, these individuals may be willing to share

with you the burden of analyzing the relevant data and communicating it to the public.

Talk with Neighboring Communities

Consult with your neighboring LEPCs, especially if you have common chemical risks and concerns. If two or more adjacent localities

have similar facilities or facilities affecting more than one LEPC, you

can split up the work of collecting and comparing RMP information.

Using fewer resources, you will be able to produce results and

share them with others. Such efforts can also serve as the basis for

risk reduction and further coordination, including joint training and

field exercises, mutual aid agreements, and pooling of financial

resources to accomplish larger-scale initiatives.

In an emergency, you may have to call on neighboring communities

for help or they may call you. In many cases, contingency plans

must include several communities to be effective. Consider the

need to:

(1) Identify whom to call in other planning districts if you need

help in an emergency;

(2) Ask them how they are funding their activities;

(3) Identify available response equipment and personnel;

(4) Negotiate procedures for mutual assistance for emergencies

that cross boundary lines;

(5) Coordinate your hazards analyses;

(6) Coordinate your review of transportation routes; and

(7) Investigate sharing computers or other resources.

In addition to these planning and response activities, talk to your

neighbors about steps you can take together to prevent chemical

accidents. You might go together to visit a facility that has a note-
page 22

worthy safety record. You might invite an expert in process safety

management to speak to a joint meeting of your LEPCs (and invite

the public to attend!). 

Each LEPC should consider its neighboring LEPCs as partners

and sources of help. Other LEPCs share your problems;

working with them may help you find common solutions.

RISK COMMUNICATION: LEPCS ARE A

BRIDGE BETWEEN THE PUBLIC AND

LOCAL INDUSTRY

Both the EPCRA and RMP regulations provide an opportunity to

promote and strengthen dialogue between the community and

industry on accident prevention and chemical emergency preparedness issues. Risk communication is an opportunity to build a

level of trust among the LEPC, companies with hazardous chemicals, and the community at large. 

One of the most important factors that affects people’s perceptions about risk is whether they feel in control. Offer

people a means to participate in decision-making about

chemicals in the community. Because LEPCs include representatives from government, industry, and citizen groups,

they offer a good setting for encouraging the different interests to work together.

Keep in mind the importance and legitimacy of public concerns

about chemicals in the community. People generally are less tolerant of risks they cannot control than of those they can. For example,

most people are willing to accept the risks of driving because they

have some control over what happens to them. However, they are

generally less comfortable accepting the risks of living near a facility that handles hazardous chemicals if they feel that they have no

control over whether the facility has an accident. The Clean Air

Act’s provision for public availability of RMPs, along with EPCRA’s

requirements for providing annual reports on hazardous chemicals,

gives the public an opportunity to take part in reducing the risk of

chemical accidents that might occur in your community.

Interested citizens may independently obtain RMPs (except for

CBI). These citizens might then ask LEPCs to explain the information in the RMPs. Although it often is left to technical experts, educating the public about risks and involving them in decisions about

what is an "acceptable" level of risk are important challenges for

LEPCs. 

Take Note

Take Note
page 23

Basic Rules of Risk Communication

Risk communication means establishing and maintaining a dialogue with the public about the chemical hazards in your community and discussing the steps that have been or can be taken to

reduce the risk posed by these hazards. There are seven “rules” of

risk communication that have been developed based on many

experiences of dealing with the public about risks.

(1) Accept and involve the public as a legitimate partner

(2) Plan carefully and evaluate your efforts

(3) Listen to the public’s specific concerns

(4) Be honest, frank, and open

(5) Coordinate and collaborate with other credible sources

(6) Meet the needs of the media

(7) Speak clearly and with compassion

There is an informal eighth rule for risk communication:

Know what you are talking about. Not everyone on the LEPC

will know everything about hazardous chemicals. Call on

chemical engineers, health professionals, scientists, and

school teachers (e.g., science, chemistry) to help you. Retired

professionals are frequently helpful.

Hazards Versus Risks

Hazards are inherent properties that cannot be changed. Chlorine

is toxic when inhaled or ingested; propane is flammable. There is

little that you can do with these chemicals to change their toxicity

or flammability. If you are in an earthquake zone or an area affected by hurricanes, earthquakes and hurricanes are hazards. When a

facility conducts its hazard review or process hazards analysis, it

will identify hazards and determine whether the potential exposure to the hazard can be reduced in any way (e.g., by limiting the

quantity of chlorine stored on-site).

Risk is usually evaluated based on several variables, including the

likelihood of a release occurring, the inherent hazards of the chemicals combined with the quantity released, and the potential impact

of the release on the public and the environment. For example, if a

release during loading occurs frequently, but the quantity of chemical released is typically small and does not generally migrate offsite,

the overall risk to the public is low (even though workers may be at

Take Note
RMPs Are on the Way!

page 24

risk). If the likelihood of a catastrophic release occurring is

extremely low, but the number of people who could be affected if it

occurred is large, the overall risk may still be low because of the low

probability that a release will occur. On the other hand, if a release

occurs relatively frequently and a large number of people could be

affected, the overall risk to the public is high.

The RMP regulation does not require facilities to assess risk in a

quantitative way because, in most cases, the data needed to estimate risk levels (for example, one in 100 years) are not available.

Even in cases where data such as equipment failure rates are available, there are large uncertainties in using those data to determine

a numerical risk level for any given facility. Therefore, you may

want to assign qualitative values (high, medium, low) to the risks

that you have identified at facilities in your community, but you

should be prepared to explain the terms if you do. For example, if

you believe that the worst-case release is very unlikely to occur,

you must give good reasons; you must be able to provide specific

examples of measures taken to prevent such a release, such as

installation of new equipment, careful training of workers, and rigorous preventive maintenance. You can ask facilities to provide

documentation to support claims about the level of risk.

Three Scenarios When You May Need to

Communicate with the Public about Chemical

Risk

Scenario A: During or immediately after an accidental

chemical release 

When there is an accident, the news media and the public always

have questions. First they might ask:

• What is going on?

• Am I or my children at risk?

• Should we evacuate or shelter in place?

• What are you doing to stop this accident from spreading?

A little while later, they might ask:

• How did this happen?

• How long will we feel “short-term” health effects?

• Are there any hidden health effects?

• What are you doing to prevent this from happening again?

Tips &

Hints

Who Will Ask Questions?

• Persons living near the

facility or working at a

neighboring facility

• Special interest groups

including environmental

organizations, police departments, zoning and planning

boards, chambers of commerce, unions, and various

civic organizations

• Journalists, reporters, and

other news media organizations

• Medical professionals, educators, and consultants
page 25

To answer questions like these, you will need to have a community

emergency plan and know the contents of that plan. Do you have a

record of chemicals in the community and what their potential

health effects are? Do you identify an emergency contact for each

facility in the community? Does your emergency plan include clear

provisions for determining whether evacuation and/or sheltering

in-place might be necessary? Has one person (or office) been

assigned to provide information to the public? Have you prepared

sample press releases so that you can quickly provide helpful

information to the public? Do you have procedures for telling the

public about upcoming LEPC meetings so that the public can attend

and ask questions? Have you worked with the mayor’s office and

local response agencies to ensure that the LEPC is the focal point

for risk communication?

Scenario B: Routine or past accidental releases of chemicals

After accidental releases, the news media and the pubic may

become more interested in chemical hazards in the community.

They may search the Toxic Release Inventory (TRI) available under

EPCRA section 313 for more information about chemical releases.

They may search for information provided under the RMP regulation about accidental releases during the past five years. This

search could lead to newspaper articles and television reports

about chemicals being released in the community. You may then

hear questions like these:

• What risk do these exposures pose for my family?

• Do these emissions affect our health?

• Why are facilities allowed to release these chemicals?

• Is the facility in compliance with federal, state, and local laws?

• Are there other facilities that should be reporting similar

events?

The LEPC might take several actions. Invite a toxicologist or a doctor to an LEPC meeting to discuss specific chemical hazards with

the public. Share your information about other facilities in the

community. Share information on the risk management program

regulation and EPCRA. Invite the facility emergency coordinator to

explain steps the facility takes to prevent serious accidents even

though there are routine releases. Work with facilities to take

action to reduce risk.
RMPs Are on the Way!

page 26

Scenario C: Chemicals Stored in the Community

The search of TRI and RMP databases could eventually lead to stories about all the chemicals stored in the community. The public

and the news media may then ask questions like these:

• Are the chemicals stored properly?

• What are the chances of dangerous chemicals leaking?

• Can these stored chemicals lead to an accident?

• If these chemicals are released, what could be the health

effects?

• Can we reduce the amount of chemicals stored in the community, and use less hazardous chemicals and inherently safe

technologies?

• What else can we do to reduce the risk of accidents?

In this instance, the LEPC can turn to all the data it has collected

from EPCRA and RMP reports. These questions can be more easily

addressed if you have one software program like CAMEO to manage data. You may also want to hold a meeting that includes facility

representatives so that everyone can discuss realistic steps to prevent accidental chemical releases in the community.

A Special Case: Dealing with Worst-Case

Scenarios

In the beginning, public interest might focus on the worst-case scenario, rather than on prevention and preparedness. Worst-case

scenario information must be explained to the public in a way that

promotes perspective and understanding, rather than confusion.

The experience of the heavily industrialized Kanawha Valley of

West Virginia illustrates how worst-case scenario data can open

lines of communication between industry and the public. Despite

fears that information on worst-case scenarios would produce

strong negative reactions toward local industry, the chemical industry worked with EPA and state and local officials to release worstcase data well ahead of the RMP rule schedule. The Safety Street

demonstration proved that the public could understand information on potential accidents and risks and act constructively. Due in

part to a pro-active approach by industry, and with the sponsorship

of the LEPC, the public evaluated the information presented to the

community and was able to take part in a constructive dialogue

with industry and public officials. 
page 27

Respond to Concerns

LEPC involvement creates a process through which people, who

otherwise might be mistrustful or even adversarial, can work

together to understand, address, and prepare for chemical risks in

the community. Sometimes, anger about what the public perceives

as risky situations arises not so much from the actual risk but from

people’s feeling that they have no control over what is happening to

them. You can reduce this by including the public as a partner in

discussions about what is an acceptable risk in your community

and how to reduce risks.

An LEPC that arms itself with basic information about the RMP program, makes an effort to look at the RMPs for facilities in the community, and encourages facilities to involve the LEPC, response

1. Open a risk management dialogue

with facility owners/operators, community leaders, and the public to

focus on risk reduction activities.

2. Understand how the public will

access information and what impact

this will have.

3. Reach out to the small business

community. Many small facilities

will not have the expertise or

resources to respond effectively to

the technical questions that their

RMPs may produce. By reaching out

to them, you can help develop a

more community-wide approach to

addressing risk management questions.

4. Identify key issues of concern in

your community. Use LEPC meetings

as a forum to collect and document

concerns, which then can be forwarded to individual facilities, as

appropriate.

5. Schedule follow-up meetings or

presentations at other public gatherings to allow LEPC and industry

representatives to respond to these

issues.

6. Draw upon sample questions and

answers contained in the Risk

Communication chapter of EPA's

General Guidance on Risk

Management Programs. Work with

industry to understand the underlying issues and develop answers to

specific questions, focusing on actual or potential risk reduction

actions.

7. Plan a special meeting to unveil

local RMPs. 

8. Work with the news media to

reach a wider audience.

9. Explore using community bulletin

boards on local access cable television stations and community

Internet sites.

Potential Risk Communication Activities
RMPs Are on the Way!

page 28

agencies, and the public in a discussion of these plans and the risks

they disclose will do a great service to the community.

IMPROVING YOUR EMERGENCY PLANS

Several elements of the RMP regulation requirements support your

local emergency planning process. The offsite consequence analysis can provide you with detailed information to continue prioritizing and planning for chemical hazards in the community. While

EPA does not consider the worst-case release scenario to be the

most realistic basis for response planning, you may be able to use

the distances or the population potentially affected to set priorities. 

The alternative release scenarios, which may be based on actual

incidents (either at the facility or within the industry as a whole) or

the results of the facility hazard evaluation, are intended to represent realistic events for planning purposes. You will want to meet

with facility officials to discuss the details in the alternative scenario(s) and work together to ensure that the community response

plan realistically addresses the alternative scenarios. This activity

will help you meet the EPCRA requirement to update your community plan annually. The alternative scenarios can also provide a

useful basis for an exercise.

The RMP regulation supplements the information-gathering authority granted under EPCRA section 303(d)(3) to local planning and

response officials. Now, in addition to EPCRA section 302 facilities,

facilities with flammable regulated substances must provide LEPCs

and emergency planners, upon request, any information necessary

for developing and implementing the community emergency

response plan. 

The emergency response program provisions of the RMP regulation

ensure that all facilities with a substantial inventory of highly

volatile flammable substances work with the fire department or the

LEPC if they also have highly toxic substances, as was done for

acutely toxic substances under EPCRA section 302. Even if the facility will not respond to a release (for example, with its own hazmat

team), it still must coordinate with you or the fire department on

response actions and ensure that a system for emergency notification is in place. This requirement means that the facility must be

certain that local responders can handle potential releases. If

responders do not have the training or equipment to respond to a

particular type of chemical release, the facility must arrange for an

appropriate response (for example, by establishing a mutual aid

agreement with an industry response team).

Tips &

Hints

Setting Priorities

Let us say there are six

facilities in your community

submitting worst-case releases scenarios for toxic regulated substances: two have

worst-case distances greater

than six miles, two have

worst-case distances of

approximately three miles,

and two report distances of

less than one mile. As a

first step, you might rank

them into three categories by

distance. A further look at

the RMP data may reveal

that the two facilities with

the greatest distances are

located more remotely from

populated areas than the two

with the smallest distances.

As a result, the former may

have estimated that their

worst case would impact a

much smaller residential

population, and the latter

may have reported that

there also are schools and a

hospital within their worstcase distance. The RMP will

provide a straightforward

way of considering these factors without having to

research or analyze the data

on your own.
page 29

WORKING WITH INDUSTRY TO

PREVENT ACCIDENTS

The RMP regulation is intended to prevent chemical accidents and

mitigate the consequences of the accidents that do occur. Facilities

will take the first step in achieving this goal when they develop and

implement their risk management program, especially in the formal

elements of the prevention program. However, the availability of

RMP information (particularly the offsite consequence analysis and

the results of the hazard evaluation) is expected to encourage the

second step of this process: an ongoing dialogue between the community and industry leading to practical changes that can reduce

the risk of a chemical accident.

As with emergency preparedness, the LEPC should serve as the

forum for the community and industry on accident prevention. You

will want to meet with facility officials to discuss the offsite consequence analysis, understand the facility’s prevention program, and

perhaps suggest additional steps to prevent accidental chemical

releases.

Using RMP*Info, the national RMP database, you will be able to

gather the information necessary to compare practices at local facilities with other facilities in the same industry in your state or even

What You’ll Find in the RMP

Based on a hazard review or process hazard analysis for each

covered process, a facility will list in the RMP:

• The regulated substances in the process;

• The NAICS code for the process;

• The major hazards of the chemicals (toxic release, fire,

explosion) and of the process (for example, overfilling,

overpressurization, runaway reaction);

• The process controls in use;

• Any mitigation systems; and

• Information on whether the facility has monitoring or

detection systems.

For Program 2 processes, the RMP will also include a list of

industry codes and standards that the facility complies with for

the process.

Tips &

Hints

With RMP data from other

facilities, you can make comparisons with a local facility

by asking the following the

questions:

• Is the quantity of the

chemical the facility is using

or storing unusual?

• Has your facility identified

the same major hazards as

similar facilities? 

• Does your facility have the

same kinds of process controls as similar facilities?

• Does your facility use the

same kind of mitigation systems as similar facilities?

• Do facilities in this industry generally have detection

systems? 

If the facility you are

reviewing has not listed

major hazards that similar

facilities have identified, this

may indicate a problem with

the facility's hazard review

or PHA. If it has fewer controls, mitigation systems, or

detection systems than similar facilities have, you may

want to talk to the facility

about possible changes that

could reduce risk.
RMPs Are on the Way!

page 30

in other parts of the country. RMP*Info will let you search on a particular chemical and NAICS code to identify other facilities that use

the same regulated substance in the same type of process as the

local facility of interest to you (for example, chlorine for water treatment). Information on the number of employees will help you

focus on facilities of similar size, which will make the comparisons

more appropriate.

If you ask local facility officials in advance, they may be willing to

provide technical or other forms of assistance to help you understand accident prevention techniques in specific industries.

Once you have a list of other similar facilities, you can print out the

RMPs or parts of the RMPs for these facilities and compare them to

the RMP for your local facility. (This could even be a good research

project for students at the local high school!) 

You may be pleasantly surprised by the results of your work; you

may find that your local facility is among the best in the nation. On

the other hand, if the local facility does not have certain process

controls or a detection system typically used by similar facilities, or

if it stores ten times as much of the regulated substance as anyone

else, you have some solid information with which to start a dialogue on risk reduction. 

In addition, keep in mind this is the first time that these types of

data have ever been collected on a national basis. In some cases,

local facilities may be very interested in what you find. Based on

the prevention programs of similar facilities in other parts of the

country, local facilities may initiate state-of-the-art accident prevention practices. 

Tips &

Hints

You might set up a public

recognition program to draw

attention to local facilities

that have especially good

accident prevention programs.
page 31

Tips &

Hints

If you anticipate implementing the RMP regulation in

your community, check

EPA's Factsheet, "Funding

Sources for Implementing the

Risk Management Program",

or the National Governors'

Association December 1997

report, State Strategies and

Considerations for Implementing the Chemical Accidental

Release Prevention Program.

A FEW MORE SUGGESTIONS

Now that you have an idea of how you can become involved in the

Risk Management Program and accident prevention, you may have

a few questions about how to proceed. The following are suggestions to help you identify resources for information, funding, and

legal issues.

Funding Your Activities

Some states and communities have appropriated general revenue

funds for LEPC activities; others are relying on implementation fees

and existing state agency budgets. Because states have limited

resources, each LEPC must find the means for achieving its goals.

Some LEPCs will do their work with little funding. Your LEPC members may already be donating their time.

EPA’s Chemical Emergency Preparedness and Prevention (CEPP)

Technical Assistance Project Grants offer funding for state, local, and

Tribal agencies for implementing the Risk Management Program

and for developing the underlying support system. Awards are

made using the Clean Air Act Section 112(1)(4) and Section

103(b)(3) authorities. These authorities allow EPA to award grants

related to the Risk Management Program directly to local governments. The grantee must provide matching funds equal to 25 percent of the total project cost. To obtain further information on the

CEPP grants, contact CEPPO.

Liability

Some LEPCs and individual LEPC members have expressed concern

that they might be held legally liable if they approve an emergency

response plan that proves to be inadequate during an accident.

Check with your SERC about your state law and ask about liability

considerations and protection. Some LEPC members have asked

whether they invite liability issues by reviewing facility RMPs.

SERCs are generally considered state agencies and are, therefore,

covered by the state’s immunity provisions. Some states have

extended this immunity to LEPCs through laws or through legal

decisions. Others have provided liability coverage for LEPCs.

LEPCs may also be able to address liability concerns by clearly stating (1) the limitations of any review they conduct of RMPs, and (2)

that they neither have nor assume any legal obligations for reviewing RMPs.
RMPs Are on the Way!

page 32

Source of Information Location and Telephone Number

My SERC

My LEPC

RMP Implementing Agency for my state

EPA Regional Contact

for EPCRA and RMP 

EPA’s Chemical Emergency Preparedness http://www.epa.gov/ceppo

and Prevention Office website

The RCRA, Superfund and Toll free: (800) 424-9346

EPCRA Hotline TDD: (800) 553-7672

Washington, DC area: 

703-412-9810

Fax: 202-651-2061

Other hotlines

Risk Management Program Resources

Handy Reference

Using the table above, fill out the information that applies in your

case, clip, and save for your use. For information about the EPA

Regional Contact, see Appendix B.
page A-1

Contents of this Section:

Appendices:

A: Checklist–Ideas for Action

B: EPA Regional Office Contacts for EPCRA

and RMP Programs

C: Some Background Information–

Comparison of Green Book and RMP

Offsite Consequence 

Analysis (OCA) Guidance Methodology

D: Regulated Substances–Chemicals

Covered by the RMP Regulation and

Their Threshold Quantities

Attachments:

• Y2K Alert

• Customer Satisfaction Survey
RMPs Are on the Way!

page A-2
page A-3

❏ Visit EPA’s chemical emergency preparedness and prevention

website at http://www.epa.gov/ceppo. This site contains all the up-todate information about both EPCRA and the RMP regulation, including

electronic copies of relevant documents.

❏ Call the RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 for

answers to your questions and for help in getting copies of documents.

❏ Identify facilities. Use the list of regulated substances at the back of

this booklet and your EPCRA section 312 reports (Tier II) to identify facilities that may be covered by the new RMP regulation. Remember, though,

that EPCRA reports provide information on chemicals for the facility as a

whole, while the RMP rule applies to a facility based on how much of a

chemical it has in a single process.

❏ Contact these facilities and see if they want to work with you in sharing RMP information in your community.

❏ Arrange public information-sharing events with interested facilities.

Consider:

• Having special LEPC meetings for this purpose;

• Having local facilities host meetings that include the LEPC

and members of the public; and

• Organizing an event at a shopping mall or auditorium at

which several facilities can discuss their RMP information

with interested local citizens.

❏ Work with facilities to: reduce chemical inventories; substitute less

hazardous chemicals; use inherently safe technologies; and add new prevention measures.

❏ Develop a public recognition program to honor your firefighters,

police department, and other first responders for their expertise in

responding to hazmat incidents. Honor facilities who have a noteworthy

accident prevention program. Honor volunteer groups like the Red Cross.

❏ Recruit effective LEPC members. Check to see if inactive members

want to continue on the LEPC. If not, take this opportunity to recruit interested and effective new members. Check with your SERC and/or neighboring LEPCs for ideas about new members.

❏ Ensure a representative LEPC. Make sure your LEPC membership is

broad-based and representative of your community.

❏ Leverage Resources. Organize your LEPC to use available resources

such as students, retired chemical engineers, chemists, health professionals, and trade and volunteer organizations.

APPENDIX A: 

CHECKLIST–IDEAS FOR ACTION ❏✓
RMPs Are on the Way!

page A-4

❏ Include small business representatives in your membership and

invite them to meetings. 

❏ Publicize the LEPC. Form a subcommittee with the assignment to make

the LEPC better known in the community. Advertise your meetings in the

newspapers and on TV and radio. Invite the news media to attend your

meetings and report on them. Tell your citizens about the information

you have about chemicals in the community.

❏ Educate the community. Form a subcommittee on public education

and information to help the public understand chemical risks in the community, to respond to requests for information about chemicals in the

community, and to involve the public in the emergency planning process

as well as chemical accident prevention activities.

❏ Review this booklet’s section on New Partnerships. Who in your

community might be interested in the LEPC and its work? 

❏ Review your current community response plan. How can it be

improved using new RMP information?

❏ Coordinate plans. Ensure that your community response plan is coordinated with the emergency response programs of facilities in the community.

❏ Develop an up-to-date list of response and mitigation equipment

in the community. Where is the equipment stored? The new RMP information should be of help to you on this task.

❏ Get training and technical assistance. Contact your SERC and/or

your EPA regional office to find out about training and other sources of

technical assistance in your area.

❏ Find the contact person. Contact your SERC and/or your EPA regional

office to find out who will be the official implementing agency for the

RMP program in your area as well as what RMP initiatives are underway

in your state.

❏ Get a copy of EPA’s Guidance for Implementing Agencies to learn

how you can get more involved in the workings of the program. You may

even decide to be the RMP implementing agency in your area.

❏ Obtain the Toxic Release Inventory (TRI) data for facilities in your

area to ensure that you have all available information about chemicals in

your community.

❏✓
page A-5

You can also consult EPA’s CEPPO website (http://www.epa.gov/ceppo) for information about Regional and state

contacts.

APPENDIX B: 

EPA REGIONAL OFFICE CONTACTS FOR EPCRA AND RMP

PROGRAMS

EPA Region

1 Maine, Vermont, New Hampshire, Massachusetts,

Connecticut, Rhode Island

2 New York, New Jersey, Puerto Rico, Virgin 

Islands

3 Delaware, Virginia, Pennsylvania, District of

Columbia, West Virginia, Maryland

4 North Carolina, South Carolina, Kentucky,

Tennessee, Georgia, Florida, Alabama, Mississippi

5 Ohio, Indiana, Illinois, Michigan, Minnesota,

Wisconsin

Point of Contact and Telephone Number

Ray DiNardo

US EPA Region 1 New England (Mail Code: SPP)

JFK Federal Building

One Congress Street

Boston, MA 02114-2023

(617) 918-1804 

John Higgins

US EPA Region 2 (Mail Code: 211)

2890 Woodbridge Avenue 

Edison, NJ 08837-3679

(732) 906-6194

David Wright

US EPA Region 3 (Mail Code: 3HW33)

1650 Arch Street 

Philadelphia, PA 19103-2029

(215) 814-3293

Bill Taylor

US EPA Region 4

Atlanta Federal Center

61 Forsyth Street, SW 

Atlanta, GA 30303

(404) 562-9167

Mark Horwitz

US EPA Region 5 (Mail Code: SC-9J)

77 West Jackson Blvd.

Chicago, IL 60604

(312) 353-9045

Continued on next page
Point of Contact and Telephone Number

Steve Mason

US EPA Region 6 (Mail Code: 6E-E)

Allied Bank Tower

1445 Ross Avenue

Dallas, TX 75202-2733

(214) 665-2292

Mark Smith

US EPA Region 7 (ARTD/CRTB)

901 N. 5th Street

Kansas City, KS 66101

(913) 551-7876

Eric Steinhaus

US EPA Region 8 (Mail Code: EPR-ER)

One Denver Place

999 18th Street, Suite 500

Denver, CO 80202-2405

(303) 312-6837

Nate Lau

US EPA Region 9 (Mail Code: SFD-5)

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-2337

Lisa McArthur

US EPA Region 10 (Mail Code: HW-093)

1200 Sixth Avenue

Seattle, WA 98101

(206) 553-0383

RMPs Are on the Way!

page A-6

EPA Region

6 Texas, Louisiana, Arkansas, Oklahoma, New

Mexico

7 Iowa, Kansas, Missouri, Nebraska

8 Colorado, Utah, North Dakota, South Dakota,

Montana, Wyoming

9 Arizona, Nevada, California, Hawaii, Guam,

America Samoa

10 Oregon, Washington, Idaho, Alaska
Green Book OCA Guidance

APPENDIX C:

SOME BACKGROUND INFORMATION–COMPARISON OF

GREEN BOOK AND RMP OFFSITE CONSEQUENCE

ANALYSIS (OCA) GUIDANCE METHODOLOGY

page A-7

Purpose

Help LEPCs conduct site-specific hazards analysis for

airborne releases of extremely hazardous substances

(EHSs) regulated under EPCRA section 302.

Help owners or operators of regulated sources to conduct offsite consequence analysis required under

CAA section 112(r).

Chemicals Covered

About 390 toxic gases, liquids, and solids.

Chemicals listed based on toxicity alone; volatility not

considered.

77 toxic gases and liquids and 63 flammable gases

and volatile, flammable liquids.

Toxic liquids (with a few exceptions) have vapor pressure at ambient temperature of at least 10 millimeters

of mercury.

Endpoints

Levels of concern (LOC) set for EHSs based on (1) onetenth of the NIOSH IDLH or (2) one-tenth of an estimated IDLH based on mammalian toxicity data.

Use of endpoints:

Use of the LOC is not required - other endpoints are

also suggested.

Toxics:

Endpoints set by rule as (1) Emergency Response

Planning Guideline Level 2 (ERPG-2) set by AIHA or (2)

EHS LOC. Many endpoints are different from EHS

LOCs.

Flammables:

Endpoints set by rule for blast overpressure from

vapor cloud explosions, heat radiation from fires, and

dispersion to the flammability limit.

Use of endpoints:

Specified endpoints must be used for consequence

analysis.

continued on next page
Green Book OCA Guidance

RMPs Are on the Way!

page A-8

Initial Screening (Green Book)/Worst-Case Releases (OCA Guidance)

Maximum quantity that could be released from largest

vessel or interconnected vessels.

Greatest quantity in a single vessel or in a pipe, considering administrative controls.

Release Rate

For Toxic Gases

Gases under ambient conditions:

Substances that are gases under ambient conditions

are assumed to be released over 10 minutes.

Liquefied refrigerated gases:

No provision for gases liquefied by refrigeration

under ambient pressure.

Mitigation:

No method provided.

Gases under ambient conditions:

Substances that are gases under ambient conditions

and are handled as gases, as liquids under pressure,

or refrigerated liquids that would form pools with a

depth of 1 cm or less upon release are assumed to be

released over 10 minutes.

Liquefied refrigerated gases:

Gases handled as refrigerated liquids at ambient

pressure that would form pools with depth greater

than 1 cm are treated as liquids.

Mitigation:

Method provided for reducing the release rate for

gases released in enclosures.

For Toxic Liquids

Liquid release:

Assumed to be instantaneous.

Release to air:

Pool evaporation; equation for pool evaporation uses

a mass transfer coefficient for water of 0.24 cm/sec.

Liquid density:

All liquids assumed to have the same density as water

for estimation of pool size.

Solutions:

No method provided for solutions.

Mitigation:

Method provided for estimating release rate from

diked area.

No method provided for mitigation of release rate for

liquids released in buildings

Temperature:

Factors provided for estimation of release rate at 25o

C

and the boiling point. 

Liquid release:

Assumed to be instantaneous.

Release to air:

Pool evaporation; equation for pool evaporation uses

a mass transfer coefficient for water of 0.67 cm/sec

(i.e., evaporation rate increased by factor of about 3

over Green Book rate).

Liquid density:

Chemical-specific density factors provided for estimation of pool size.

Solutions:

Method and data provided for estimating release

rates for common water solutions and oleum.

Mitigation:

Method provided for estimating release rate from

diked area.

Method provided for reducing the release rate for liquids released in buildings.

Temperature:

Factors provided for estimation of release rate at 25o

C

and the boiling point. Factors generally significantly

larger than Green Book factors because of revised

mass transfer coefficient and revised chemical-specific

data.

Temperature correction factors provided for temperatures between 25 and 50o

C.

Quantity Released
Green Book OCA Guidance

page A-9

Initial Screening (Green Book)/Worst-Case Releases (OCA Guidance)–continued

For Toxic Solids

Solids with particle size 100 microns or less or solids

in solution assumed released in 10 minutes; factors

provided for release rate estimation for molten solids.

None regulated.

Flammable Substances

Not covered. Vapor cloud explosion of entire quantity assumed,

with yield factor of 10%. 

Meteorological Conditions

F stability, wind speed 3.4 miles per hour (1.5 meters

per second).

F stability, wind speed 1.5 meters per second.

Modeling Conducted

Neutrally buoyant gases and vapors:

Gaussian model used for neutrally buoyant plumes.

• Continuous releases assumed, even for 10-minute

releases.

Dense gases and vapors:

No dense gas modeling.

(Note: The RMP Rule requires consideration of gas

density for offsite consequence analysis)

Neutrally buoyant gases and vapors:

Gaussian model used for neutrally buoyant plumes.

• 10-minute releases; i.e., release assumed to stop

after 10 minutes (with 10-minute averaging time).

• 60-minute releases (with 30-minute averaging

time).

Dense gases and vapors:

SLAB model used for dense gases.

• 10-minute releases (with 10-minute averaging

time).

• 60-minute releases (with 30-minute averaging

time).

Vapor cloud explosions:

TNT-equivalent model used for vapor cloud explosions.

Distance Tables Provided

Neutrally buoyant plume table only:

Rural conditions only for screening.

Generally gives significantly greater distances for the

same release rate and toxic endpoint than the OCA

Guidance tables.

(Note: The RMP Rule requires that rural or urban

topography be used, as appropriate.)

Toxics:

Neutrally buoyant plume tables:

• Rural - 10 minute and 60 minute.

• Urban - 10 minute and 60 minute.

Dense gas tables:

• Rural - 10 minute and 60 minute.

• Urban - 10 minute and 60 minute.

Chemical-specific tables:

• Ammonia liquefied under pressure.

• Ammonia solution.

• Chlorine.

• Sulfur dioxide.

Flammables: 

Vapor cloud explosion distance table. 

Maximum Distance in Tables

10 miles 25 miles
RMPs Are on the Way!

page A-10

Green Book OCA Guidance

Reevaluation (Green Book)/Alternative Scenario Analysis (OCA Guidance)

Quantity Released

Estimate quantity based on site-specific information. Estimate quantity based on site-specific information.

Release Rate

For Toxic Gases

Estimate release rate based on site-specific information.

Specific methods not provided.

Mitigation:

No method provided.

Gases under pressure:

Estimation methods for:

• Gaseous release from tank (based on hole size and

tank pressure.

• Gaseous release from pipe.

• Release of gas liquefied under pressure:

- from vapor space,

- from liquid space.

Liquefied refrigerated gases:

Gases handled as refrigerated liquids at ambient

pressure are treated as liquids.

Mitigation:

Method provided for reducing the release rate for

gases released in enclosures.

Active mitigation measures also discussed. 

For Toxic Liquids

Liquid release:

Estimate release rate based on site-specific information.

Liquid density:

Not considered.

Solutions:

No method provided for solutions.

Release to air:

Pool evaporation, as for screening

Mitigation:

Same as for screening.

Temperature:

Same as for screening.

Liquid release:

Estimation methods for:

• Release from tank under atmospheric pressure.

• Release from pressurized tank.

• Release from pipe.

Liquid density:

Considered as for worst case.

Solutions:

Considered as for worst case. 

Release to air:

Pool evaporation, as for worst case

Mitigation:

Same methods for passive mitigation as for worst

case.

Active mitigation for liquid release and for release to

air discussed.

Temperature:

Same as for worst case.

For Toxic Solids

Estimate release rate based on site-specific information.None regulated.
page A-11

Green Book OCA Guidance

Flammable Substances

Not covered Methods provided for:

• Vapor cloud fires.

• Pool fires.

• BLEVEs.

• Vapor cloud explosions, based on less conservative

assumptions than the worst case.

Meteorological Conditions

D stability, wind speed 11.9 miles per hour (5.3 meters

per second) or same conditions as for screening.

D stability, wind speed 3 meters per second.

Distance Tables Provided

Neutrally buoyant plume tables only:

Rural (screening conditions and D stability, higher

wind speed).

Urban (screening conditions and D stability, higher

wind speed).

Toxics:

Neutrally buoyant plume tables:

• Rural - 10 minute and 60 minute.

• Urban - 10 minute and 60 minute.

Dense gases:

• Rural - 10 minute and 60 minute.

• Urban - 10 minute and 60 minute.

Chemical-specific tables:

• Ammonia liquefied under pressure.

• Ammonia solution.

• Chlorine.

• Sulfur dioxide.

Flammables: 

Vapor cloud explosion distance table.

Vapor cloud fire distance tables:

• Neutrally buoyant plumes.

• Dense gases.

BLEVE (fireball) distance table.

10 miles 25 miles

Reevaluation (Green Book)/Alternative Scenario Analysis (OCA Guidance)–cont.

Maximum Distance in Tables
RMPs Are on the Way!

page A-12
Regulated Substance CAS # TQ

Acrolein 107-02-8 5,000

Acrylonitrile 107-13-1 20,000

Acrylyl chloride 814-68-6 5,000

Allyl alcohol 107-18-6 15,000

Allylamine 107-11-9 10,000

Ammonia (anhydrous) 7664-41-7 10,000

Ammonia (conc. 20% or greater) 7664-41-7 20,000

Arsenous trichloride 7784-34-1 15,000

Arsine 7784-42-1 1,000

Boron trichloride 10294-34-5 5,000

Boron trifluoride 7637-07-2 5,000

Boron trifluoride compound

with methyl ether (1:1) 353-42-4 15,000

Bromine 7726-95-6 10,000

Carbon disulfide 75-15-0 20,000

Chlorine 7782-50-5 2,500

Chlorine dioxide 10049-04-4 1,000

Chloroform 67-66-3 20,000

Chloromethyl ether 542-88-1 1,000

Chloromethyl methyl ether 107-30-2 5,000

Crotonaldehyde 4170-30-3 20,000

Crotonaldehyde, (E)- 123-73-9 20,000

Cyanogen chloride ((CN)Cl) 506-77-4 10,000

Cyclohexylamine 108-91-8 15,000

Diborane 19287-45-7 2,500

Dimethyldichlorosilane 75-78-5 5,000

1,1-Dimethylhydrazine 57-14-7 15,000

Epichlorohydrin 106-89-8 20,000

Ethylenediamine 107-15-3 20,000

Ethyleneimine 151-56-4 10,000

Ethylene oxide 75-21-8 10,000

Fluorine 7782-41-4 1,000

Formaldehyde (solution) 50-00-0 15,000

Furan 110-00-9 5,000

Hydrazine 302-01-2 15,000

Hydrochloric acid 

(conc. 30% or greater) 7647-01-0 15,000

Hydrocyanic acid 74-90-8 2,500

Hydrogen chloride (anhydrous) 7647-01-0 5,000

Hydrogen fluoride/Hydrofluoric acid 

(conc. 50% or greater) 7664-39-3 1,000

Regulated Substance CAS # TQ

Hydrogen selenide 7783-07-5 500

Hydrogen sulfide 7783-06-4 10,000

Iron, pentacarbonyl- 13463-40-6 2,500

Isobutyronitrile 78-82-0 20,000

Isopropyl chloroformate 108-23-6 15,000

Methacrylonitrile 126-98-7 10,000

Methyl chloride 74-87-3 10,000

Methyl chloroformate 79-22-1 5,000

Methyl hydrazine 60-34-4 15,000

Methyl isocyanate 624-83-9 10,000

Methyl mercaptan 74-93-1 10,000

Methyl thiocyanate 556-64-9 20,000

Methyltrichlorosilane 75-79-6 5,000

Nickel carbonyl 13463-39-3 1,000

Nitric acid (conc. 80% or greater) 7697-37-2 15,000

Nitric oxide 10102-43-9 10,000

Oleum (fuming sulfuric acid) 8014-95-7 10,000

Peracetic acid 79-21-0 10,000

Perchloromethyl mercaptan 594-42-3 10,000

Phosgene 75-44-5 500

Phosphine 7803-51-2 5,000

Phosphorus oxychloride 10025-87-3 5,000

Phosphorus trichloride 7719-12-2 15,000

Piperidine 110-89-4 15,000

Propionitrile 107-12-0 10,000

Propyl chloroformate 109-61-5 15,000

Propyleneimine 75-55-8 10,000

Propylene oxide 75-56-9 10,000

Sulfur dioxide (anhydrous) 7446-09-5 5,000

Sulfur tetrafluoride 7783-60-0 2,500

Sulfur trioxide 7446-11-9 10,000

Tetramethyllead 75-74-1 10,000

Tetranitromethane 509-14-8 10,000

Titanium tetrachloride 7550-45-0 2,500

Toluene 2,4-diisocyanate 584-84-9 10,000

Toluene 2,6-diisocyanate 91-08-7 10,000

Toluene diisocyanate 

(unspecified isomer) 26471-62-5 10,000

Trimethylchlorosilane 75-77-4 10,000

Vinyl acetate monomer 108-05-4 15,000

continued on next page

page A-13

APPENDIX D: 

REGULATED SUBSTANCES–CHEMICALS COVERED BY

THE RMP REGULATION AND THEIR THRESHOLD 

QUANTITIES

This list is current at the time of publication of this booklet. For an up-to-date list at any time, consult EPA’s CEPPO

website at www.epa.gov/ceppo.

Toxics
Regulated Substance CAS # TQ

Acetaldehyde 75-07-0 10,000

Acetylene 74-86-2 10,000

Bromotrifluoroethylene 598-73-2 10,000

1,3-Butadiene 106-99-0 10,000

Butane 106-97-8 10,000

1-Butene 106-98-9 10,000

2-Butene 107-01-7 10,000

Butene 25167-67-3 10,000

2-Butene-cis 590-18-1 10,000

2-Butene-trans 624-64-6 10,000

Carbon oxysulfide 463-58-1 10,000

Chlorine monoxide 7791-21-1 10,000

2-Chloropropylene 557-98-2 10,000

1-Chloropropylene 590-21-6 10,000

Cyanogen 460-19-5 10,000

Cyclopropane 75-19-4 10,000

Dichlorosilane 4109-96-0 10,000

Difluoroethane 75-37-6 10,000

Dimethylamine 124-40-3 10,000

2,2-Dimethylpropane 463-82-1 10,000

Ethane 74-84-0 10,000

Ethyl acetylene 107-00-6 10,000

Ethylamine 75-04-7 10,000

Ethyl chloride 75-00-3 10,000

Ethylene 74-85-1 10,000

Ethyl ether 60-29-7 10,000

Ethyl mercaptan 75-08-1 10,000

Ethyl nitrite 109-95-5 10,000

Hydrogen 1333-74-0 10,000

Isobutane 75-28-5 10,000

Isopentane 78-78-4 10,000

Isoprene 78-79-5 10,000

Isopropylamine 75-31-0 10,000

Isopropyl chloride 75-29-6 10,000

Methane 74-82-8 10,000

Methylamine 74-89-5 10,000

3-Methyl-1-butene 563-45-1 10,000

2-Methyl-1-butene 563-46-2 10,000

Methyl ether 115-10-6 10,000

Methyl formate 107-31-3 10,000

2-Methylpropene 115-11-7 10,000

1,3-Pentadiene 504-60-9 10,000

Pentane 109-66-0 10,000

1-Pentene 109-67-1 10,000

2-Pentene, (E)- 646-04-8 10,000

2-Pentene, (Z)- 627-20-3 10,000

Propadiene 63-49-0 10,000

Propane 74-98-6 10,000

Propylene 115-07-1 10,000

Regulated Substance CAS # TQ

Propyne 74-99-7 10,000

Silane 7803-62-5 10,000

Tetrafluoroethylene 116-14-3 10,000

Tetramethylsilane 75-76-3 10,000

Trichlorosilane 10025-78-2 10,000

Trifluorochloroethylene 79-38-9 10,000

Trimethylamine 75-50-3 10,000

Vinyl acetylene 689-97-4 10,000

Vinyl chloride 75-01-4 10,000

Vinyl ethyl ether 109-92-2 10,000

Vinyl fluoride 75-02-5 10,000

Vinylidene chloride 75-35-4 10,000

Vinylidene fluoride 75-38-7 10,000

Vinyl methyl ether 107-25-5 10,000

RMPs Are on the Way!

page A-14

Flammables
THE YEAR 2000

(Y2K) PROBLEM

I

t is 11:59 p.m. on December 31, 1999.

The Year 2000 problem (also known as

the “millennium bug”) could disrupt

your chemical process and storage operations. Is your facility prepared? Here are

some examples of what could happen. 

◆ A safety system, designed to detect

emissions of deadly hydrogen sulfide

gas, shut down during a Y2K test on an

oil rig in the North Sea.

◆ At a smelter in New Zealand, all the

process controls stopped working at midnight on December 31, 1996, because

programmers had failed to take into

account that 1996 was a leap year. The

loss of process control damaged equipment valued approximately at $600,000.

◆ A utility company in Hawaii ran tests on

its system to see if it would be affected by

the Y2K bug. The entire system shut

down.

At any size company, the Y2K issue could

threaten worker and community safety and

health. It could cause complete shutdowns

of machinery or safety-related systems or

could generate erroneous information (e.g.,

wrong temperature) which could lead an

operator to take unsafe or improper steps.

For chemical process industries, the Y2K

problem could increase the potential for

process shutdowns and accidental chemical releases.

This alert raises awareness about the Y2K

problem and offers a strategy to address the

problem. However, given that the Year

2000 is approaching soon, facilities should

dedicate increasingly more efforts on

developing contingency plans to prepare

for unanticipated events like those above.

Contingency planning is especially important for facilities that have not started or

have made little progress in assessing and

remediating the Y2K problem.

In addition to administrative and management systems, (payroll, financial records,

inventory), the Y2K problem could affect

three parts of your facility - your software,

your control/process equipment, and critical services provided to you by others such

as utilities and feedstock suppliers.

YOUR SOFTWARE

The Y2K dilemma is the result of a standard practice used in software programming. To save memory space and keep

costs down, computer programs and

microchips were traditionally designed to

recognize only the last two digits of a year.

This means that when the year 2000 rolls

around, computers may not be able to distinguish whether 00 means 1900 or 2000.

This could cause computer programs to

crash and systems to shut down. For example, if you rely on computer systems to

notify you to schedule maintenance or

retire equipment, the system may not properly notify you because the computer cannot recognize dates after December 31,

1999. See the “Dates to Watch” box for a

few other dates that might cause problems.

PREVENT YEAR 2000 CHEMICAL

EMERGENCIES

The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort

to protect human health and the environment by preventing chemical accidents. Alerts are

issued when EPA becomes aware of a significant hazard. It is important that facilities, State

Emergency Response Commissions (SERCs), Local Emergency Planning Committees

(LEPCs), emergency responders and others review this information and take appropriate

steps to minimize risk. The Alert is targeted at the chemical process industry to increase

awareness of the potential for chemical safety problems due to upcoming date changes.

United States Office of Solid Waste EPA 550-F-99-003

Environmental Protection and Emergency Response February 1999

Agency (5104) www.epa.gov/ceppo

Chemical Emergency Preparedness and Prevention Office Printed on recycled paper

CHEMICAL

SAFETY

ALERT
YOUR CONTROL/PROCESS

EQUIPMENT

Even if your operations do not directly use computers, some of your control machinery, process equipment, automation equipment (e.g., valves, pumps),

and emergency protection equipment (e.g., fire and

gas detectors), may be embedded with computer

chips that are date-sensitive. If these chips misunderstand the date change, the equipment could fail

or malfunction, causing process upsets that lead to

accidents. For example, an automatic valve with an

embedded chip could fail in such a way that the

valve turns off the feedstock supply. Because Y2K

problems can affect so many devices, cascading

failures are possible.

YOUR SERVICE PROVIDERS

The Y2K problem can affect manufacturing, electric utilities and energy suppliers, water utilities,

telecommunications, transportation, and other sectors that are critical to your facility operations.

Disruption of these services can become your problem. For example, a water supply utility could shut

down, causing loss of critical cooling water to

chemical reactor systems. Most plants also have

suppliers that produce raw and in-process materials

that are vital to running their processes. Many

plants have customers who accept products through

“just-in-time” delivery schedules. Failure to

receive these materials could result in safety hazards at your plant.

HAZARD AWARENESS

AND REDUCTION

The Y2K concern is real, and the solution may

not be easy. However, the effort now to

identify and fix the problem will reduce the

risk of more costly impacts of business disruptions,

safety failures, and accidental chemical releases.

While many large companies in the chemical industry already have started addressing the Y2K problem, many small businesses are just beginning to

realize the impact that the Y2K problem may have

on their operations. 

STEPS TO ADDRESS THE PROBLEM

There are several steps you can take to identify and

address the Y2K problem. Throughout this step

process, you should be sure to document what you

have done. For additional help in performing these

steps, you could contact an appropriate association,

trade group, or industry colleague for particular suggestions and best practices for your industry. If you

are unable to implement these steps in-house, consider using an outside consultant. There is also a

wealth of information on how to follow these steps

(See the “Information Resources” at end of Alert).

1. Identify and check systems for Y2K compliancy.

Each company should check its systems to determine if they are Y2K compliant. Make a list of the

date-dependent components of your systems that

are likely to be affected by the “millennium bug.”

(See box on “Examples of Equipment to Check”).

Focus on software and equipment with embedded

chips, and ask yourself if your equipment or systems use or depend on date information, for example, does the system order/retrieve information by

date, or perform date-based calculations? Prioritize

the items on your list based on their potential for

causing health, safety, and environmental concerns

and how critical they are to business production.

You should review your risk assessments or hazard

analyses (e.g., HAZOP) to be certain that Y2K vulnerable equipment and devices are inventoried and

addressed. Starting with the most critical equipment, check with your supplier, installer, or manufacturer to determine if the system component is

SOME DATES TO WATCH

✔ Sept. 9, 1999: Many computer systems

use 9/9/99 as file purge date

✔ Jan. 1, 2000: Rollover may halt, confuse,

or otherwise disrupt many systems and

devices

✔ Feb. 29, 2000: Many systems may not

recognize 2000 as a leap year 

✔ Oct. 10, 2000: First time date field uses

maximum length

✔ Dec. 31, 2000: Some systems may not

recognize the 366th day

2 Prevent Year 2000 Chemical Emergencies February 1999
Y2K compliant (see section on “Information

Resources” for some vendor web sites).

2. Remedy problem. If critical equipment can be

affected by the Y2K problem, you have several

options including repairing, modifying, or replacing

the equipment. Where mission-critical systems

cannot be assessed, remediated, and corrected, you

could consider operating the system in a manual

over-ride mode. Staff would need training on new

equipment or refresher training on procedures for

manual operation. Additional staff may be needed

when automated processes are switched to manual.

3. Test systems. Your systems and equipment should

be tested to make sure the Y2K malfunction is remedied. Do not forget to test dates other than January 1,

2000 (see the “Dates to Watch” box). Before you test,

alert local emergency officials and make sure your

employees and community are prepared for any possible failures that may have an adverse effect on health

and safety or the environment. (See EPA’s new

enforcement policy on Y2K testing in section “It’s Your

Duty”).

4. Develop and implement contingency plans.

Contingency plans are essential in your strategy to

address the Y2K problem. Even if you believe your

system is Y2K compliant, you should develop a

Y2K contingency plan to prepare for unanticipated

problems. Your contingency plan should not depend

on backup equipment and systems that could also

fail because of the Y2K complication (e.g., backup

generator, automatic shutdown system). Also, you

may need to address staffing and training for meeting Y2K contingency plans and to handle disruptions to transportation infrastructure and telecommunications. Facilities should not overlook the possibility that non-Y2K compliant computers and

chips in telecommunications and radio may prevent

police, fire, and mutual aid assistance from arriving

promptly or at all. Inform local officials concerned

with emergency situations when testing equipment,

and involve employees in planning for testing and in

responding to unexpected system changes. As part

of your contingency planning you could:

◆ Work with and share solutions and lessons

learned with your partners, suppliers, neighbor

facilities, associations, and customers to ensure

that they, too, are addressing the Y2K issue.

◆ Work with your SERC, LEPC, and other off-site

emergency management support to review

emergency response procedures and ensure that

the procedures and resources available cover

possible Y2K consequences.

◆ Make sure employees are trained and prepared

to shut down the process manually, if necessary.

◆ Consider scheduling downtime and maintenance over the end of 1999 and beginning of

2000. During shutdowns, systems can be isolated and Y2K tested. However, before you

schedule downtime, recognize that startups and

shutdowns have their own risks which must be

balanced against the potential risks from Y2K

problems. Also, if you are a large power user,

notify your utility if you plan to have a shutdown. Utilities could have operating problems

if power demands unexpectedly drop, particularly if many facilities shut down.

◆ Have a full staff available for a number of hours

just before and after critical date changes for

EXAMPLES OF EQUIPMENT TO CHECK

✔ Controllers

✔ Alarms

✔ Lighting

✔ Robots

✔ Air monitoring/leak detection devices

✔ Hazard communication databases

✔ Underground storage tank monitors

✔ Security systems

✔ Generators

✔ Lab instruments

✔ Environmental control systems

✔ Controllers for refrigeration, valves,

pumps, sensors and analyzers

✔ Programmable control systems

✔ Safety shutdown systems

✔ Fire detection systems

✔ Explosion suppression systems

✔ Elevators

✔ Conveyors

✔ Vehicles

3 Prevent Year 2000 Chemical Emergencies February 1999
unanticipated emergencies.

◆ Consider conducting an exercise using a Y2K

scenario to improve emergency response capabilities. One community, Lubbock, Texas,

already has successfully conducted such an

exercise and learned a number of important

lessons, including the need to prevent emergency communications failure.

Remember, in terms of contingency planning, facilities should take advantage of the one positive piece

of information that the Y2K problem offers us: the

ability to know when it will occur. 

IT'S YOUR DUTY

Under the General Duty Clause of the Clean

Air Act (CAA section 112(r)(1)), owners and

operators of facilities with hazardous substances have a general duty to prevent and mitigate

accidental releases, including those caused by Y2K

failures. Also, under EPA’s Risk Management

Program (RMP) Rules (CAA section 112(r)(7)), accidental release scenarios related to Y2K problems

(e.g., loss of utilities, interruption of raw material

deliveries, failure of monitoring devices) would be

reasonable alternative scenarios to consider. The

public may view any Y2K-related operating problems that occur in January 2000 as a test of the quality and reliability of your RMP. In addition, EPA has

initiated an enforcement policy designed to encourage prompt testing of computer-related equipment to

ensure that environmental compliance is not impaired

by the Y2K computer bug. Under this policy, EPA

intends to waive 100% of the civil penalties and recommend against criminal prosecution for environmental violations caused by tests designed to identify

and eliminate the Y2K-related malfunctions. This

policy is limited and subject to certain conditions.

(See complete policy on EPA’s Year 2000 web site

listed in “Information Resources.”)

The Occupational Safety and Health Act (OSHA)

has a similar General Duty Clause (section 5(a)(1))

for protection of employees from hazardous situations involving the use of highly hazardous substances. Also, OSHA’s Process Safety Management

(PSM) Standard is intended to prevent or minimize

injury to employees from accidents (including

those caused by Y2K problems) involving highly

hazardous chemicals.

INFORMATION RESOURCES

Below are some resources that will help you to

get started to address the Y2K problem at

your facility. Future updates of this resource

list can be found at the EPA CEPPO Website below.

Environmental Protection Agency (EPA)

Provides information on EPA’s efforts to address the Year

2000 problem. This includes EPA’s Y2K enforcement policy,

and under the heading “Environmental Y2K Sectors,” the

Office of Water guidance for wastewater systems (including a

checklist of basic systems) and the Office of Solid Waste flyer

on waste management and the Y2K problem.

http://www.epa.gov/year2000/

EPA’s Office of Solid Waste and Emergency Response Y2K

information.

http://clu-in.com/y2k.htm

EPA’s Chemical Emergency Preparedness and Prevention

Office (CEPPO) has this Y2K alert and updates.

http://www.epa.gov/ceppo

Occupational Safety and Health Administration (OSHA)

The OSHA web site has a bulletin on Y2K.

http://www.osha.gov/Y2knews.pdf

Chemical Safety and Hazard Investigation Board (CSB)

The CSB has sponsored a conference and report on the Y2K

problem and the potential for accidental chemical releases.

Relevant Year 2000 sites can be found on the CSB Web site by

clicking on Chem Links and then searching on “Year 2000.”

http://www.chemsafety.gov

U.S. Small Business Administration (SBA)

This web site offers information specific to helping small

businesses address the Y2K problem. It provides a list of

questions to help identify date-sensitive equipment. SBA also

has an extensive list of links to major corporations that post

their Y2K status online.

http://www.sba.gov/y2k/

Hotline: 1-800-U-ASK-SBA (1-800-827-5722)

General Accounting Office 

Guide: “Year 2000 Computing Crisis: Business Continuity

and Contingency Planning” has general principles for use by

businesses as well as government agencies.

http://www.gao.gov/special.pubs/bcpguide.pdf

National Institute of Occupational Safety & Health (NIOSH) 

NIOSH has Y2K case studies, a web forum, vendor list, and

an equipment manufacturer directory.

http://www.cdc.gov/niosh/y2k/y2k-hmpg.html

4 Prevent Year 2000 Chemical Emergencies February 1999
Health & Safety Executive (UK) 

The British Health and Safety Executive web site offers several reports on the Y2K problem. Of particular interest to the

chemical industry is “Health and Safety and the Year 2000

Problem - Guidance on Year 2000 Issues As They Affect

Safety-Related Control Systems” and “Contingency Planning

for a Safe Year 2000.”

http://www.open.gov.uk/hse/dst/2000indx.htm

National Fire Data Center

A basic system check that can help you determine if your

organization’s computer system is Y2K compliant is available

on this website. 

http://www.usfa.fema.gov/y2k/y2kcom.htm

Electronic Systems Center of the Air Force Materiel

Command (site maintained by Mitre Corporation) 

The site provides information on Y2K certification, compliance, solutions, testing and evaluations, contingency plans,

cost estimation, tools and services.

http://www.mitre.org/technology/y2k

National Institute of Standards and Technology

The site has links to free software tests, self-help tools and

product compliance status databases for use in Y2K assessment, testing, contingency planning and remediation.

Information is provided for smaller manufacturers through the

Manufacturing Extension Partnership, a nationwide network

of centers providing technical and business assistance to

smaller manufacturers. Small manufacturing firms can call 1-

800-MEP-4MFG.

http://www.nist.gov/y2k

President’s Council on Year 2000 Conversion-Product

Compliance Information

The site has a list of computer manufacturers’ Y2K sites.

http://www.y2k.gov/java/product_compliance.html

Mary Kay O’Connor Process Safety Center

The site has links to compliance status of some manufacturers’ control systems. Click on Y2K information.

http://process-safety.tamu.edu/y2k/y2k.htm

Chemical Manufacturers Association (CMA) Survey 

CMA has developed a standard survey form for the use of its

members. This survey package is designed to help companies

assess Y2K efforts of critical suppliers and customers and

minimize the risk of service interruption. The survey (posted

on 12/14/98) can be found in the “What’s New” section of the

CMA website. 

http://www.cmahq.com

Case Study of One Chemical Manufacturer’s Approach to

Y2K Problem

http://www.dell.com/smallbiz/y2k/studies.htm#merisol

American Petroleum Institute

The site provides industry activities, company status reports,

Y2K database, and technical links.

http://www.api.org/ecity/y2k/index.html

Year 2000

The site has a list of Year2000 vendors and consultants.

http://www.year2000.com

National Bulletin Board for Year 2000

Provides tools for analysis, conversion, and testing for Y2K

problems.

http://it2000.com/solutions/index.html

Y2K Freeware and Shareware

http://www.aphis.usda.gov/y2k/wares.html

Year 2000 Embedded Systems Vendors, Associations, and

Manufacturers

http://ourworld.compuserve.com/homepages/roleigh_martin/y

2k_com.htm

Some PC Test Results for Y2K Problems

http://www.hqisec.army.mil/y2kweb/y2kresults.html

http://www.nim.com.au/year2000/ye02001.htm

5 Prevent Year 2000 Chemical Emergencies February 1999

FOR MORE INFORMATION...

CONTACT THE EMERGENCY PLANNING AND COMMUNITY

RIGHT-TO-KNOW HOTLINE

800 424-9346 OR (703) 412-9810

TDD (800) 553-7672

MONDAY-FRIDAY, 9 AM TO 6 PM, EASTERN TIME

TO OBTAIN COPIES OF THIS PUBLICATION, CONTACT NATIONAL

SERVICE CENTER FOR ENVIRONMENTAL PUBLICATIONS

(NSCEP) PHONE: 800-490-9198 FAX: 513-489-8695

http://www.epa.gov/ncepihom

VISIT THE CEPPO HOME PAGE ON THE WORLD WIDE WEB AT:

http://www.epa.gov/ceppo

◆◆◆

NOTICE 

The statements in this document are intended solely as guidance. This document does not substitute for EPA's or other agency regulations, nor is it a regulation itself. Site-specific application of the guidance may vary depending on process activities, and may not apply

to a given situation. EPA may revoke, modify, or suspend this guidance in the future, as appropriate.
6 Prevent Year 2000 Chemical Emergencies February 1999

United State Environmental

Protection Agency

(5104)

Washington, DC 20460

Official Business

Penalty for Private Use

$300
CUSTOMER SATISFACTION SURVEY–CEPPO PUBLICATION 

RMPS ARE ON THE WAY!

The opinions of our customers are very important to us. Now that you have read the LEPC Guidance, please take

a few minutes to give us some feedback. The responses will be confidential, and the information you provide will

enable us to better meet your future needs. We at CEPPO want to be sure that we are developing the products

and providing the information you require.

Responding to this customer satisfaction survey is voluntary. Upon completion please remove the survey card

from the Guidance Document, fold, and mail to the address shown on the back of this page. 

Language and Format

1. Please rate the readability of the LEPC Guidance:

❏very easy to understand

❏easy to understand

❏average

❏difficult to understand

❏very difficult to understand

2. The format/layout of the LEPC guidance is:

❏very clear

❏somewhat clear 

❏somewhat unclear

❏very unclear

❏no opinion

Usefulness of the Information

3. Overall, the information is:

❏very useful

❏useful

❏slightly useful

❏not at all useful

❏no opinion

4. What is your level of satisfaction with the 

guidance?

❏very satisfied

❏satisfied

❏neither satisfied nor dissatisfied

❏dissatisfied

❏very dissatisfied

5. What is your reaction to the descriptions of the

various roles and responsibilities involved in the

RMP program (e.g., LEPC, state, region, HQ, facilities,

communities)?

❏very satisfied

❏satisfied

❏neither satisfied nor dissatisfied

❏dissatisfied

❏very dissatisfied

6. The sections on “opportunities” that the RMP

information provides for you and your LEPC to

assess and enhance preparedness and prevention

in your community are:

❏very useful

❏useful

❏slightly useful

❏not at all useful

❏no opinion

7. The amount of information in the Guidance is:

❏too much

❏just enough

❏too little

7a. If dissatisfied, what information would you add

or delete? 

_________________________________________

_________________________________________

8. Did the Guidance provide you with enough information about whom to contact if you have questions or need more information?

❏yes

❏no opinion

❏no

8a. If no, what other information would be useful? 

_________________________________________

_________________________________________

Please provide any additional comments you may

have about the LEPC Guidance to: 

Bill Finan, CEPPO (MC 5104)

USEPA

401 M St., SW

Washington, D.C. 20460

(202)260-0030

Thank you for your time.

✁
RMPs Are on the Way!

Form Approved OMB Control No. 2090-0019. Approval expires 10/31/1999

Public reporting burden for this collection of information is estimated to average five (5) minutes per response, including the time for

reviewing instructions, gathering information, and completing and reviewing the collection of information. Send comments on the

Agency?s need for this information, the accuracy of the provided burden estimates, and any suggestions for reducing the burden,

including the use of automated collection techniques to the Director, OPPE Regulatory Information Division, United States

Environmental Protection Agency (Mail Code 2137), 401 M Street, SW, Washington, D.C. 20460; and to the Office of Information &

Regulatory Affairs, Office of Management & Budget, 725 17th Street, NW. Washington, DC 20503, Attention: Desk Officer for EPA. Include

the OMB Control Number in any correspondence.

Place

stamp

here

U.S. Environmental Protection Agency

ATTN: Chemical Emergency Preparedness and Prevention Office

Program Implementation and Coordination Division

MC 5104

401 M Street, SW

Washington, DC 20460

United States

Environmental Protection 

Agency (5104)

Washington, DC 20460

Official Business

Penalty for Private Use

$300