Many businesses are asked by the EPA to submit a risk management plan. Reasons can vary from the type of business, to threshold amounts of certain chemicals such as ammonia ,chlorine, or any flammable fuel, but whatever the case, businesses are required to respond and usually within a specific deadline. Creating an RMP requires that you evaluate your risk, work on emissions and exposure control, monitor any risks, and communicate any risks. Each of these are very important and should be outlined in your RMP during submission.
Classifying and testing hazardous materials in any environment is the first step of risk assessment and management. In this case, it is up to any business owner to take responsibility for minimizing the danger and reducing the harmful effects of chemicals and substances harmful to human and ecological health. It is important to use resources such as the eChemPortal, the OECD Existing Chemicals Database and the OECD Test Guidelines, for finding and assessing the toxicology of known chemicals being used in the environment. These resources allow users to find, classify, and test out new chemicals according to EPA and OECD standards as well as to find and classify current chemicals according to hazard to air, water, and people. For flammables like propane, this risk management includes leakage, fire hazard, and any other additional damage that could be caused by the material. Essentially the first step is to figure out anything that could go wrong and record it.
After evaluating your risks, an RMP requires you to outline how you intend to control and reduce these risks. In some cases this is a simple matter of better containment in EAP approved storage. In other cases it may include reducing chemical waste, changing chemicals used in processing, or completely altering processes. In most cases, it means learning more about the hazards using tools and books. The United Nations Economic Commission recommends the ‘Globally Harmonized System of Classification and Labelling of Chemicals‘ as a good start. The eventual result of controlling environmental risk factors in your environment is that you should introduce safety and containment standards, even for non-threshold amounts of chemicals. Technical risk reduction such as better tools and equipment can also be helpful or even mandatory.
Once you have recognised risks, it is up to you to monitor them in order to ensure that they stay contained. This involves learning about the worst case scenario side effects and what preventive measures could be taken in case of those side effects. For example, utilising tools to scope the breadth and impact of a hazard can help with reduction. These tools include items like Sanborn maps for seeing fire hazards that might be heightened by any chemicals you have, parcel platforms for local area assessment, or even tools to help build models and calculate risk based on specific conditions. For example, monitoring local fire risk areas using Sanborn maps allows businesses to keep track of and mitigate their risks by identifying potential problems in advance.
For many businesses, monitoring also includes keeping track of specific levels of air, water, and ground pollutants in order to keep them under a specified minimum that does not damage or harm local wildlife or local inhabitants. This type of monitoring is typically overseen by localised government as well as Federal government and standards are typically set by area and by chemical rather than one given standard.
Finally, your RMP has to talk about your plans of communicating your environmental risks. This involves discussing issues with risk assessors and potentially submitting to inspections, working with the media for full disclosure of any risks, and keeping interested groups as well as the general public fully informed of risks you present. Full disclosure is required by Federal law, and most RMPs require that you talk about it.
Risk management is a very scientific process so the RMP must fully outline everything you intend to do as part of your risk management plan. Start with an executive summary that covers the basics and then go into details for the nine sections of the RMP. In addition, you must update this document a minimum of every five years in order to stay current. If you’re looking for a quick risk assessment tool to get started, the OECD offers one for free that you can see here. The EPA also provides a full list of information that you have to fill out in the RMP to help you with your documents and data.
About the Author
Marshall Peterson is an environmental specialist in northern California specializing in risk management services. When not working, he spends his time writing blog posts like this one and gardening.