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General Guidance on EPA’s Risk Management Program Requirements and Toluene Diisocyanate (TDI) 

The purpose of this document is to provide general guidance on Section 112(r) of the Clean Air Act (CAA). Section 112(r) of the CAA requires the Environmental Protection Agency (EPA) to promulgate regulations for the prevention and mitigation of accidental releases of extremely hazardous substances. Under this section, EPA established a list of regulated substances and thresholds and issued the Chemical Accident Prevention Provisions (40 CFR Part 68). The goals of this program are to prevent accidental releases of chemicals that could cause serious harm to human health or the environment and to reduce the severity of releases that may occur.

Covered facilities are required to develop and implement a risk management program that includes a five-year accident history, an offsite consequence analysis, an accident prevention program, and an emergency response program. Regulated facilities must submit to EPA a risk management plan (RMP) describing the source’s risk management program (40 CFR 68.115). EPA provides an online tool called “RMP*eSubmit” to allow facilities to prepare and submit their RMPs online.

The Chemical Accident Prevention provisions also require full updates and resubmissions of RMPs at least once every five years. Certain processes and other changes may require a facility to fully update or resubmit its RMP prior to the five-year anniversary of the RMP. The five-year anniversary date is reset whenever companies fully update and resubmit their RMPs.

On April 9, 2004, EPA amended the RMP rule (69 FR 18819). The amendment requires more timely accident history reporting and corrections to emergency contact information; removes the requirement to briefly describe the results of off-site consequence analysis in the Executive Summaries of RMPs; and adds three new data elements to RMPs.

American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.

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