Our national tragedy has increased everyone's awareness of site security
and vulnerability to physical threats. This is especially true for
municipal water treatment plants.
Counter-terrorism activities for the water industry commenced several years
ago and are now beginning to show results.
PROPOSED CHANGES TO EPA'S RISK MANAGEMENT PROGRAM WILL AFFECT THOUSANDS
OF FACILITIES
- This involves 2004 and future RMP Plan Submittals.
- The EPA is in the process of making changes to the Risk Management
Program (RMP).
- It will affect each facility subject to 40 CFR 1910-68.
- We understand the critical nature of your RMP program and the EPA report
requirement changes. Though these changes are still being formulated,
we have noted the key elements that will affect all RMP subject
facilities. These elements are numbered like the EPA proposal and
include:
- Discussion of Proposed Changes
- RMP Plant Submission Requirement
- If facility has an EPA-recordable accident, the RMP Plan must be
revised and resubmitted to the EPA within six months of the
incident. This includes updating the Five-Year Accident History.
- Emergency contact information has to be corrected within one month
of a change. This would require a resubmission of the emergency
contact information only as a correction to the original RMP Plan.
- Changes to the Executive Summary
- Remove the brief description of the off-site consequence analysis
and the alternative release scenario from the RMP Executive Summary.
- Addition of New Data Elements to the RMP Plan Submittal
- Emergency contact e-mail address (if any) will be a required field.
- Purpose of submission data field will be to have a pop-up field to
identify whether the submission is a new, updated or corrected RMP plan
submittal.
- Identification of contractors who help prepare the RMPs must be
identified, (similar to listing the name of the accountant who does your
federal tax return).
- Revisions to the RP Submit Format:
- Will include a space for Uncontrolled/Runaway Reactions as a possible
cause of an accidental release.
- Other issues which may be added to the RMP Submit:
- Include listing the OSHA Occupational Injury and Illness Data with the
RMP filing requirement. This includes the Total Incident Rate,
workdays lost to injuries and illness and work days on restricted duty.
(Many municipalities are exempt from and do not keep OSHA injury
records. However, municipalities may keep similar data, which could
be used.)
- The document also includes background information and advice on RMP plan
submittals. We will advise you as soon as the EPA promulgates the
final changes from the proposed list above.
If you need any guidance or updates on the RMP program please
contact us.
A proactive Risk Management Program (RMP) and Process Safety Management
Program (PSM), becomes:
- First step to implement and keep current facility policies and procedures
which are the basis of facility safety systems.
- D. E. I., Inc. will help improve your site security program.
- We can help you conduct a hazards analysis, audit your programs and train
your staff.
- We can provide information and guidance on needed actions in light of
the new initiatives by the EPA and other government entities.
We have provided links to websites of some of the key agencies and groups
dealing with improving our safety.
A FEW BUSINESSES THAT WE WORK WITH:
Incident Management Team
Your Partner in Crisis Management
Lone Wolf Technologies
Providing solutions to Industries' water and waste water needs with
innovative technologies that are "ahead of the pack"!
Metallurgical Viability, Inc.
A Process Engineering Company Specializing
in Process Economics
Sullivan Environmental Consulting, INC
Air quality consulting services
nationwide and in some cases internationally
Sun State Specialty K-9s, Inc.
K-9 Prevention & Detection Services -
"Have Dogs....Will Travel!"
LINKS TO RELATED COUNTER TERRORISM AND SECURITY TOPICS:
EPA counter terrorism and security resources and information:
www.epa.gov/ebtpages/emercounter-terrorism.html
yosemite.epa.gov/oswer/CeppoWeb.nsf/content/index.html
www.epa.gov/safewater/security/
Internet Security:
www.sans.org/top20/
Presidential Document on Infrastructure:
www.ciao.gov/
Association of Metropolitan Water Agencies (AMWA) information:
www.awwa.org/
www.amwa.net/isac/watercip.html
Indications, Analysis & Warning Program:
www.amwa.net/isac/ciplinks.html
Electrical Industry information on reporting sabotage incidents:
www.nerc.com
www.awwa.org/prepare/
