United States

Environmental Protection

Agency

Office of Solid Waste

and Emergency Response

(5104)

EPA 550-B-00-009

May 2000

www.epa.gov/ceppo/

RMP SERIES

Chemical Emergency Preparedness and Prevention Office Printed on recycled paper

RISK MANAGEMENT

PROGRAM GUIDANCE

FOR

WAREHOUSES

(40 CFR PART 68)
May 26, 2000
May 26, 2000

This document provides guidance to help owners and operators of stationary sources to

determine if their processes are subject to chemical accident prevention regulation under section

112(r) of the Clean Air Act and 40 CFR part 68 and to comply with regulations. This document

does not substitute for EPA’s regulations, nor is it a regulation itself. Thus, it cannot impose

legally binding requirements on EPA, states, or the regulated community, and may not apply to a

particular situation based upon circumstances. The guidance does not represent final agency

action, and EPA may change it in the future, as appropriate.
May 26, 2000

FOR UPDATES

To keep up to date on changes to this document and to the risk management program rule, and to

find other information related to part 68 and accident prevention, visit EPA’s Chemical Emergency

Preparedness and Prevention Office website at: 

www.epa.gov/ceppo/

THIS EDITION

This document is a revision of the January 1999 Risk Management Program Guidance for Warehouses.

The revisions are needed to reflect several amendments to 40 CFR part 68 as well as to reflect the

availability of the software for submission of RMPs. The specific regulatory changes include the

following:

g The change from SIC codes to NAICS codes to define the industrial sectors subject to

Program 3;

g The adoption of rules for confidential business information;

g Changes to the way in which flammable liquids and refrigerated flammable gases may be

modeled for the offsite consequence analysis; and

g Changes to coverage for flammable fuels.

The revisions also update items, such as web page addresses, where needed. Pages that include

substantive revisions to the previous text are noted by a new date in the footer. Appendices C and D in

the 1999 document, which provided EPA and OSHA contacts, have been eliminated; addresses for

websites that provide this information and are updated frequently are included in the Technical

Assistance appendix. 
May 26, 2000
May 26, 2000

TABLE OF CONTENTS

INTRODUCTION

CHAPTER 1 GENERAL APPLICABILITY

1.1 Introduction 1-1

1.2 General Provisions 1-3

1.3 Regulated Substances and Thresholds 1-5

1.4 What is a Process 1-5

1.5 Threshold Quantity in a Process 1-8

1.6 Stationary Source 1-14

1.7 When Must You Comply 1-15

1.8 Varying Inventories and Predictive Filing 1-17

CHAPTER 2 APPLICABILITY OF PROGRAM LEVELS

2.1 What Are Program Levels 2-1

2.2 Program 1 2-3

2.3 Quick Rules for Determining Program 1 Eligibility 2-9

2.4 Program 3 2-10

2.5 Program 2 2-11

2.6 Dealing with Program Levels 2-12

2.7 Summary of Program Requirements 2-15

CHAPTER 3 FIVE-YEAR ACCIDENT HISTORY

3.1 What Accidents Must Be Reported 3-1

3.2 What Data Must Be Provided 3-1

3.3 Other Accident Reporting Requirements 3-9

CHAPTER 4 OFFSITE CONSEQUENCE ANALYSIS

4.1 Worst-Case Release Scenarios 4-4

4.2 Alternative Scenarios 4-13

4.3 Buildings 4-20

4.4 Estimating Offsite Receptors 4-21

4.5 Documentation 4-24

Appendix 4A Reference Tables of Distances and Tables of Data from the Offsite Consequence Analysis

Guidance 4-27

CHAPTER 5 MANAGEMENT SYSTEM

5.1 General Information (§ 68.15) 5-1

5.2 How to Meet the Management System Requirements 5-1
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CHAPTER 6 PREVENTION PROGRAM (PROGRAM 2)

6.1 About the Program 2 Prevention Program 6-1

6.2 Safety Information (§ 68.48) 6-2

6.3 Hazard Review (§ 68.50) 6-7

6.4 Operating Procedures (§ 68.52) 6-11

6.5 Training (§ 68.54) 6-15

6.6 Maintenance (§ 68.56) 6-17

6.7 Compliance Audits (§ 68.58) 6-20

6.8 Incident Investigation (§ 68.60) 6-21

6.9 Conclusion 6-25

CHAPTER 7 PREVENTION PROGRAM (PROGRAM 3)

7.1 Prevention Program 3 and OSHA PSM 7-1

7.2 Process Safety Information (§ 68.65) 7-3

7.3 Process Hazard Analysis (§ 68.67) 7-5

7.4 Operating Procedures (§ 68.69) 7-9

7.5 Training (§ 68.71) 7-10

7.6 Mechanical Integrity (§ 68.73) 7-10

7.7 Management of Change (§ 68.75) 7-11

7.8 Pre-Startup Review (§ 68.77) 7-13

7.9 Compliance Audits (§ 68.79) 7-13

7.10 Incident Investigation (§ 68.81) 7-13

7.11 Employee Participation (§ 68.83) 7-14

7.12 Hot Work Permits (§ 68.85) 7-15

7.13 Contractors (§ 68.87) 7-15

Appendix 7-A PHA Techniques 7-18

CHAPTER 9 EMERGENCY RESPONSE

8.1 Non-Responding Sources (§ 68.90(b)) 8-1

8.2 Elements of an Emergency Response Program (§ 68.95) 8-2

8.3 Developing an Emergency Response Program 8-6

8.4 Integration of Existing Program 8-9

8.5 Am I Already in Compliance 8-9

8.6 Coordination with Local Emergency Planning Committees 8-12

CHAPTER 9 RISK MANAGEMENT PLAN (Part 68, Subpart G)

9.1 Elements of the RMP 9-1

9.2 RMP Submission 9-2

9.3 Issues Pertaining to Submission of and Access to Confidential Business Information and Trade

Secrets 9-3

9.4 Resubmission and Updates 9-4
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May 26, 2000

CHAPTER 10 IMPLEMENTATION

10.1 Implementing Agency 10-1

10.2 Reviews/Audits/Inspections (§ 68.220) 10-2

10.3 Relationship with Title V Permit Programs 10-4

10.4 Penalties for Non-Compliance 10-4

CHAPTER 11 COMMUNICATION WITH THE PUBLIC

11.1 Basic Rules of Risk Communication 11-1

11.2 Sample Questions for Communicating with the Public 11-4

11.3 Communication Activities and Techniques 11-13

11.4 For More Information 11-19

APPENDICES

APPENDIX A PART 68

APPENDIX B SELECTED NAICS CODES

APPENDIX C TECHNICAL ASSISTANCE

APPENDIX D OSHA GUIDANCE ON PSM
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May 26, 2000

LIST OF BOXES AND EXHIBITS

LIST OF EXHIBITS

CHAPTER 1

Exhibit 1-1 Evaluate Facility to Identify Covered Processes

Exhibit 1-2 Process

Exhibit 1-3 Stationary Source

CHAPTER 2

Exhibit 2-1 Evaluate Program Levels for Covered Processes

Exhibit 2-2 Program Level Criteria

Exhibit 2-3 Develop Risk Management Program and RMP

Exhibit 2-4 Comparison of Program Requirements

CHAPTER 3

Exhibit 3-1 Atmospheric Stability Classes

CHAPTER 4

Exhibit 4-1 Examples of Regulated Toxic Substances in Warehouses

Exhibit 4-2 Examples of Regulated Flammable Substances in Warehouses

Exhibit 4-3 Required Parameters for Modeling

Exhibit 4-4 Predicted Distances to Toxic Endpoints for Regulated Toxic Materials

Exhibit 4-5 Predicted Distances to Toxic Endpoints for Regulated Toxic Materials

Exhibit 4-6 Predicted Distances to Toxic Endpoints for Regulated Toxic Materials

CHAPTER 5

Exhibit 5-1 Sample Management Documentation

CHAPTER 6

Exhibit 6-1 Summary of Program 2 Prevention Program

Exhibit 6-2 Safety Information Requirements

Exhibit 6-3 Codes and Standards

Exhibit 6-4 Sample Safety Information Sheet

Exhibit 6-5 Hazard Review Requirements

Exhibit 6-6 Sample Checklist

Exhibit 6-7 Operating Procedures Requirements

Exhibit 6-8 Training Chart 

Exhibit 6-9 Maintenance Guidelines

Exhibit 6-10 Sample Audit Checklist for Safety Information and Hazard Review

Exhibit 6-11 Incident Investigation Requirements

Exhibit 6-12 Sample Incident Investigation Format
v

May 26, 2000

CHAPTER 7

Exhibit 7-1 Comparable EPA and OSHA Terms 

Exhibit 7-2 Summary of Program 3 Prevention Program 

Exhibit 7-3 Process Safety Information Requirements

Exhibit 7-4 Process Hazard Analysis Requirements

Exhibit 7-5 Operating Procedures Requirements

Exhibit 7-6 Mechanical Integrity Chart

Exhibit 7-7 Management of Change Requirements

Exhibit 7-8 Pre-startup Review Requirements

Exhibit 7-9 Incident Investigation Requirements

Exhibit 7-10 Employee Participation Requirements

Exhibit 7-11 Hot Work Permits Requirements

Exhibit 7-12 Contractors Chart

Exhibit 7A-1 Applicability of PHA Techniques

Exhibit 7A-2 Time and Staffing for PHA Techniques

CHAPTER 8

Exhibit 8-1 Federal Guidance on Emergency Planning and Response

Exhibit 8-2 Federal Emergency Planning Regulations

CHAPTER 9

Exhibit 9-1 RMP Updates

CHAPTER 11

Exhibit 11-1 Seven Cardinal Rules of Risk Communication

LIST OF BOXES

INTRODUCTION

State Programs

If You Are New to Regulations

What Is a Local Emergency Planning Committee?

CHAPTER 1

State Programs

Qs and As: Stationary Source

Aggregation of Substances

Qs and As: Threshold Determinations

Qs and As: Consideration of Products

Qs and As: Stationary Source

Qs and As: Compliance Dates 

CHAPTER 2

Q and A: Process and Program Level

Qs and As: Public Receptors
vi

May 26, 2000

Q and A: Determining Distances

Q and A: Environmental Receptors

Qs and As: Accident History

Qs and As: OSHA

CHAPTER 3

Q and A: Property Damage

Qs and As: Accident History

CHAPTER 4

RMP*Comp

How to Obtain Census Data and Landview

How to Obtain USGS Maps

CHAPTER 6

Q and A: Audits

CHAPTER 7

Q and A: Implementation and Program Level

Qs and As: Process Safety Information

Qs and As: Offsite Consequences

CHAPTER 8

What Is a Response

What Is a Local Emergency Planning Committee?

Qs and As: Emergency Response and Warehouses

Planning for Flammable Substances

CHAPTER 9

Qs and As: RMP Updates

Q and A: Revising a PHA

CHAPTER 10

Qs and As: Delegation

Qs and As: Audits

CHAPTER 11

What Does Your Worst-case Release Distance Mean?

What Does It Mean That We Could Be Exposed If We Live/Work/Shop/Go to School X Miles Away?

If There Is an Accident, Will Everyone Within That Distance Be Hurt? What about Property Damage?

How Sure Are You of Your Distances?

What Are You Doing to Prevent Releases?

What Are You Doing to Prepare for Releases?

Why Are Your Distances Different from the Distances in the EPA Lookup Tables?

How Likely Are the Worst-case and Alternative Release Scenarios?

Is the Worst-case Release You Reported Really the Worst Accident You Can Have?
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May 26, 2000

What about the Accident at the [Name of Similar Facility] That Happened Last Month?

What Actions Have You Taken to Involve the Community in Your Accident Prevention and Emergency

Planning Efforts?

Can We See the Documentation You Keep on Site?
viii

May 26, 2000
ix

May 26, 2000

TABLE OF POTENTIALLY REGULATED ENTITIES

This table is not intended to be exhaustive, but rather provides a guide for readers

regarding entities likely to be regulated under 40 CFR part 68. This table lists the types

of entities that EPA is now aware could potentially be regulated by this rule and covered

by this document. Other types of entities not listed in this table could also be affected. 

To determine whether your facility is covered by the risk management program rules in

part 68, you should carefully examine the applicability criteria discussed in Chapter 1 of

this guidance and in 40 CFR 68.10, which is available in Appendix A of this document . 

If you have questions regarding the applicability of this rule to a particular entity, call

the EPCRA/CAA Hotline at (800) 424-9346 (TDD: (800) 553-7672)(see Appendix C,

Technical Assistance, for other sources of information).

Category NAICS

Codes

SIC

Codes

Examples of Potentially Regulated Entities

Warehouses 49311

49312

49319

4225

4222

4226

General warehousing and storage

Refrigerated warehousing

Other warehousing and storage
x

May 26, 2000