If an emergency strikes your facility, do you have plans in place that can minimize damage and liability to the company? What emergencies could happen?

Recently Houston fire officials determined that a blast at a facility in West Houston caused by a propylene leak destroyed the facility, caused damage to more than 200 homes, and killed two people. Propylene — a chemical regularly used at the facility and many other similar facilities — is a hazardous chemical covered by several federal environmental and worker safety regulations. If a company stores more than 10,000 pounds of propylene, it is required to file a Risk Management Plan (RMP) with the Environmental Protection Agency (EPA). The company in question had no RMP filed with the EPA, although the facility exceeded that amount for the chemical.

如我们以前所提到的那样万博app手机版官网下载, hurricanes, floods, water inundation, dangerous gas leaks, explosions, and everything in-between occur regularly in the U.S. and across the world. Houston and the Gulf Coast experienced several major chemical explosions and fires in the last year alone. RMPs help businesses prepare for what may go wrong in smaller events (e.g., small spills, injuries, chemical releases), or large events such as these.

Provisions for facilities that require an RMP:

•RMP.Rulewas built upon existing industry codes and standards. It requires facilities that use listed regulated Toxic or Flammable Substances for Accidental Release Prevention to develop an RMP and submit that plan to EPA.
•需要在一个过程中持有超过阈值数量的设施，以遵守EPA的风险管理计划规定。
•该规则包括一个规定的物质清单under section 112(r) of the Clean Air Act, including their synonyms and threshold quantities (in pounds) to help assess if a process is subject to the RMP rule.
•监管的物质也受清洁空中行为的要求一般职责条款.

RMP规则特别需要使用极具危险物质的设施来开发RMP，其中：

• Identifies the potential effects of a chemical accident
• Identifies steps the facility is taking to prevent an accident
• Spells out emergency response procedures should an accident occur

While not specifically mentioned by emergency responders, the presence of more than 10,000 pounds of propylene also triggers the Process Safety Management (PSM) requirements of the Occupational Safety and Health Administration (OSHA), which has similar requirements as EPA’s RMP rule, except the focus is on worker safety.

Companies that are not required to have an RMP or PSM program are usually required to submit a Tier II Chemical Inventory Report, which aids local responders during an emergency. Events in the last year, such as the Intercontinental Terminal Company fire and the West Houston explosion, emphasize the utility of this compliance information for firefighting personnel and the public. Tier II information is specifically useful when battling chemical fires. The facility should have listed the propylene on their Tier II chemical inventory report, and firefighters and the local community should have been notified that this facility handled this material and in what capacity.

Would the explosion have been prevented if the facility had these plans?

如果该设施符合EPA的RMP标准，他们将进行流程危险审查以确定潜在的情景，并评估最小化风险所需的保障措施。在Tier II库存报告中添加丙烯可能没有阻止事故，但会为当地紧急响应者提供机会为此类事件做好准备。此外，具有良好调整的合规计划可以帮助确定泄漏的风险并在达到最终导致设施破坏和多重死亡的尺寸之前防止它。

What happens if you fail to report?

如果您有灾难性的事件，则不可避免地，紧急响应者和监管机构将发现不合规。当地应急计划委员会（LEPC）可以提出民事诉讼，EPA或国家可以评估未能报告的罚款。此外，国家监管机构表示他们有意升级检查以确定不遵守Tier II报告。这意味着设施足以避免灾难性事件仍然有可能面临监管行动。

Ultimately, the fallout from an emergency event can haunt a company for years after. RMPs, PSM programs and Tier II reports are relatively inexpensive to implement, and utilizing them can stimulate productive conversation about what chemicals are used, if they’re necessary, and if using them at a capacity that requires an RMP, PSM program, or Tier II reporting is appropriate.

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