Smith Group
Consulting, LLC
Risk Management
Smith Group Consulting, LLC

Copyright 2007-2008
Smith Group Consulting, LLC
4738 Moss Creek Ct., Suite 200
Indianapolis, IN 46237
If your facility uses large tanks of such common chemicals
such as ammonia or chlorine, you need to complete Risk
Management Planning as required by federal law. Dozens of
other chemicals are also covered by the Clean Air Act.

Smith Group Consulting can help evaluate your facility to
determine whether it is covered by the Risk Management
requirement. If Risk Management Planning is required, Smith
Group Consulting is your best choice for meeting the
requirements of U.S. Code of Federal Regulations, Part 68 (40
CFR 68). See below for more on these requirements.

An estimated 68,000 facilities in the United States, including
many water and wastewater treatment plants, are covered by
the RMP Rule. These facilities were required to implement a
full RMP and submit a summary of it to a central location
specified by EPA no later than June 20, 1999.

Risk Management Regulations
On June 20, 1996, the U.S. Environmental Protection Agency
(EPA) published the final rule for the Clean Air Act (CAA)
Section 112 (r). This rule is called the Risk Management Plan
Rule (RMP Rule) of Title 40 of the U.S. Code of Federal
Regulations, Part 68 (40 CFR 68).

Chemical Safety
Failure to meet the RMP requirements can subject a facility to
a penalty of $25,000 per day for each violation of the Act.

The purpose of the CAA is to complement the chemical
safety work begun under the Emergency Planning and
Community Right-to-Know Act (EPCRA) and the Process
Safety Management (PSM) regulations of the Occupational
Safety and Health Administration (OSHA).

The CAA includes elements of both Risk Management
Planning and Process Safety Management. Risk Management
Plans are within the jurisdiction of EPA, and Process Safety is
covered by OSHA. In Indiana, IOSHA is responsible for
Process Safety.

Because RMP is designed to protect the public from releases
of toxic chemicals and PSM is intended to protect employees,
the Threshold Quantities (TQ) for some chemicals are not the
same on EPA and OSHA Toxic Chemical lists. For instance,
the TQ for chlorine on EPA’s RMP list is 2,500 pounds,
while the TQ for OSHA 1,500 pounds.