Emergency Response Program

DOE-HDBK-1101-96

Emergency Response Program

An emergency response program also must be developed. The applicable emergency response

program requirements are much more stringent under the proposed EPA RMP than those under

OSHA's PSM rule. OSHA's emergency action plan regulation basically requires an evacuation plan.

Whereas, under the EPA rule, facilities will need to develop a more extensive emergency response

plan. This emergency response plan must detail how the facility would respond to a release to limit

offsite consequences. Conducting drills and exercises to test the emergency response plan(s) and

coordination of plans with the Local Emergency Planning Committee (LEPC) are also proposed.

Coordination with the LEPC is not required by OSHA although many facilities do so currently.

RMP and Documentation

The proposed EPA RMP Rule would require facilities to prepare and submit the RMP to different

agencies. The EPA is proposing that a RMP be submitted to Chemical Safety and Hazard

Investigation Board, the State Emergency Response Commission, the LEPC, and made available to

the public. The RMP would include the results of the risk management program elements, a copy of

the registration, description of the management system, and certification of the accuracy and

completeness of the information. Facilities would be required to maintain the documentation

supporting the implementation of the risk management plan for inspection by EPA and other

agencies.

Registration

The RMP Rule would require facilities to register with the EPA if they have a regulated substance in

a quantity greater than the threshold quantity. The proposed rule requires facilities to register with

the EPA within three years of the date of the publication of the final rule. The content of the

registration would include the name and address of the facility, the facility's Dun and Bradstreet

number, the regulated substances on site and the quantities, and the facility's Standard Industrial

Code (SIC) that apply to the use of each regulated substance. Most of these registration

requirements are already reported under the SARA Title III.

If the information on registration changes (e.g. quantity change, new chemicals added, chemicals are

no longer used) after the submittal of the registration, facilities would be required to file an amended

registration form within 60 days.

C-4