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Do You Use, Store, Manufacture, Distribute or Handle Toxic or Flammable Substances?
What You Need to Know About Risk Management Planning

July 1997

If you own or operate a facility that uses, stores, manufactures, distributes or handles regulated toxic and flammable substances, it is your responsibility to identify and assess your chemical hazards and carry out certain activities designed to reduce the likelihood and severity of accidental chemical releases.

Risk Management Planning for the accidental release of chemicals, as required in Section 112(r) of the amended Clean Air Act, is imperative to protecting the health of your workers, the surrounding community and the environment.

On June 20, 1996, the U.S. Environmental Protection Agency (EPA) announced a final regulation requiring risk management planning to help prevent accidental releases of hazardous chemicals. The risk management planning requirements of the Clean Air Act (CAA), Section 112(r), complement and support the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) by making public information available on chemical risk and ways to reduce it.

As an owner or operator of a facility that manufactures, stores, distributes, handles, or uses regulated toxic or flammable substances above certain threshold quantities (10,000 lbs. for all flammables and ranging from 500 to 20,000 pounds for toxic substances), it is your responsibility to comply with this planning requirement by June 21, 1999. While this compliance date is nearly two years away, Section 112(r) is complicated and will require an extensive amount of work to determine the applicable requirements and to develop a compliance plan.

Following this fact sheet is a list of 139 regulated toxic and flammable substances. Carefully read the list and determine if you manufacture, store, distribute, handle, or use any of these substances. (Refer to Section II "Hazardous Ingredients" of your required Material Safety Data Sheets [MSDSs] or other product data sheets to find out what chemicals are contained in your process materials. For more information about how to interpret a MSDS, view the fact sheet "How to Read a Materials Safety Data Sheet".)

For each chemical you use that is on the attached list, determine how much of the substance is on-site at any time and compare that quantity with the threshold quantity (provided on the list) for that particular substance. At any time throughout the calendar year, if on-site quantities (measured in lbs.) are above the established threshold quantities, you must comply with this risk management planning requirement.

Once you determine that 112(r) compliance is necessary, the next step is to identify all specific requirements that apply. The requirements vary from facility to facility and will depend on what "program" description (below) applies to your facility.

Most small businesses need to comply with the requirements in either Program 1 or Program 2. All regulated facilities that meet the criteria for complying with Section 112(r), regardless of program, must prepare a Risk Management Plan. The difference between the programs is the complexity of the prevention and emergency response programs in the Risk Management Plan. The Risk Management Plan must be updated every five years or when another regulated substance exceeds the threshold. Facilities are required to register with EPA, meet all the requirements in their applicable program (see the table below) and have the Risk Management Plan completed by the compliance date of June 21, 1999.

This table outlines the core activities that you need to conduct to be in compliance with Program 1 or Program 2 of Section 112(r).

table - program requirements

 

AN ALTERNATIVE: POLLUTION PREVENTION

Conducting the detailed requirements of the Risk Management Plan can be overwhelming for a business owner. However, there may be action you can take — for example, stop using the toxic materials that are regulated. Eliminating or minimizing the use of toxic substances is among the actions the actions known as "pollution prevention." The following pollution prevention opportunity can help your company:

• meet federal regulations and cut your paperwork burden;
• reduce costs by using fewer raw materials;
• reduce waste transportation and disposal costs; and
• cut liability and insurance costs.

 

ELIMINATE USING REGULATED CHEMICALS

There are several approaches to eliminating the use of products that contain regulated chemicals. Following are some suggestions:

Talk to your suppliers. Explain to them your interest in finding a way to eliminate the use of regulated chemicals. Ask if they supply other products that can get the job done but do not contain regulated chemicals or have harmful health effects. If your suppliers don't have any suggestions, get recommendations from your peers or potential new suppliers.
Inquire about changing customer specifications. If external specifications require that you use a product containing regulated chemicals, ask the customer if a change would be acceptable. Propose a viable alternative that will reduce both your and their liability while improving the safety of the workplace.
Ask for help from government technical assistance programs. You can get recommendations for alternative, non-regulated products, as well as help estimating air pollution emissions or other assistance, from government technical assistance programs.

 

ENFORCEMENT

Your local, state and federal regulatory agencies are determining who is going to administer this rule. Contact your Compliance Assistance contact listed below for a copy of the requirements and further updates.

 

Toxic Substances — Threshold Quantity

Chemical Name CAS No. (lbs.)
Acrolein [2-Propenal] 107-02-8 5,000
Acrylonitrile [2-Propenenitrile] 107-13-1 20,000
Acrylylchloride [2-Propenoyl chloride] 814-68-6 5,000
Allylalcohol [2-Propen-1-ol] 107-18-61 5,000
Allylamine [2-Propen-1-amine] 107-11-9 10,000
Ammonia (anhydrous) 7664-41-7 10,000
Ammonia (conc 20% or greater) 7664-41-7 20,000
Arsenoustrichloride 7784-34-11 5,000
Arsine 7784-42-1 1,000
Borontrichloride [Borane,trichloro-] 10294-34-5 5,000
Borontrifluoride [Borane, trifluoro-] 7637-07-2 5,000
Borontrifluoride compound with methyl ether(1:1) [Boron, trifluoro[oxybis[metane]]-,T-4- 353-42-4 15,000
Bromine 7726-95-6 10,000
Carbondisulfide 75-15-0 20,000
Chlorine 7782-50-5 2,500
Chlorinedioxide [Chlorineoxide(ClO2)] 10049-04-4 1,000
Chloroform [Methane,trichloro-] 67-66-3 20,000
Chloromethylether [Methane, oxybis[chloro-] 542-88-1 1,000
Chloromethylmethylether [Methane, chloromethoxy-] 107-30-2 5,000
Crotonaldehyde [2-Butenal] 4170-30-3 20,000
Crotonaldehyde, (E)-[2-Butenal,(E)-] 123-73-9 20,000
Cyanogenchloride 506-77-4 10,000
Cyclohexylamine [Cyclohexanamine] 108-91-8 15,000
Diborane 19287-45-7 2,500
Dimethyldichlorosilane [Silane, dichlorodimethyl-] 75-78-5 5,000
1,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-] 57-14-71 5,000
Epichlorohydrin [Oxirane, (chloromethyl)-] 106-89-8 20,000
Ethylenediamine [1,2-Ethanediamine] 107-15-3 20,000
Ethyleneimine [Aziridine] 151-56-4 10,000
Ethyleneoxide [Oxirane] 75-21-8 10,000
Fluorine 7782-41-4 1,000
Formaldehyde (solution) 50-00-0 15,000
Furan 110-00-95,000
Hydrazine 302-01-215,000
Hydrochloric acid (conc 30% or greater) 7647-01-0 15,000
Hydrocyanic acid 74-90-82,500
Hydrogenchloride (anhydrous) [Hydrochloric acid] 7647-01-0 5,000
Hydrogenfluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] 7664-39-3 1,000
Hydrogenselenide 7783-07-5 500
Hydrogensulfide 7783-06-4 10,000
Iron,pentacarbonyl- [Ironcarbonyl(Fe(CO)5),(TB-5-11)-] 13463-40-6 2,500
Isobutyronitrile [Propanenitrile, 2-methyl-] 78-82-0 20,000
Isopropylchloroformate [Carbonochloridic acid, 1-mehtylethylester] 108-23-6 15,000
Methacrylonitrile [2-Propenenitrile, 2-methyl-] 126-98-7 10,000
Methylchloride [Methane,chloro-] 74-87-3 10,000
Methylchloroformate [Carbonochloridic acid,methylester] 79-22-1 5,000
Methylhydrazine [Hydrazine,methyl-] 60-34-41 5,000
Methylisocyanate [Methane, isocyanato-] 624-83-9 10,000
Methylmercaptan [Methanethiol] 74-93-1 10,000
Methylthiocyanat [Thiocyanic acid, methylester] 556-64-9 20,000
Methyltrichlorosilane [Silane, trichloromethyl-] 75-79-6 5,000
Nickel carbonyl 13463-39-3 1,000
Nitric acid (conc 80% or greater) 7697-37-2 15,000
Nitric oxide [Nitrogen oxide (NO)] 10102-43-910,000
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]1 8014-95-7 10,000
Peracetic acid [Ethaneperoxoic acid] 79-21-0 10,000
Perchloromethylmercaptan [Methanesulfenyl chloride, trichloro-] 594-42-3 10,000
Phosgene [Carbonic dichloride] 75-44-5500
Phosphine 7803-51-25,000
Phosphorus oxychloride [Phosphoryl chloride] 10025-87-35,000
Phosphorus trichloride [Phosphorous trichloride] 7719-12-21 5,000
Piperidine 110-89-415,000
Propionitrile [Propanenitrile] 107-12-0 10,000
Propyl chloroformate [Carbonochloridic acid, propylester] 109-61-515,000
Propyleneimine [Aziridine, 2-methyl-] 75-55-8 10,000
Propylene oxide [Oxirane, methyl-] 75-56-9 10,000
Sulfur dioxide (anhydrous) 7446-09-5 5,000
Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-] 7783-60-0 2,500
Sulfur trioxide 7446-11-9 10,000
Tetramethyllead [Plumbane, tetramethyl-] 75-74-1 10,000
Tetranitromethane [Methane, tetranitro-] 509-14-8 10,000
Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-] 7550-45-0 2,500
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-]1 584-84-9 10,000
Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-]1 91-08-710,000
Toluene diisocyanate (unspecified isomer)[Benzene, 1,3-diisocyanatomethyl-]1 26471-62-5 10,000
Trimethylchlorosilane [Silane, chlorotrimethyl-] 75-77-4 10,000
Vinyl acetate monomer [Acetic acid ethenyl ester] 108-05-4 15,000
1 The mixture exemption in 68.115(b)(1) does not apply to the substance.

 

Flammables — Threshold Quantity

Chemical Name CAS No. (lbs.)
Acetaldehyde 75-07-0 10,000
Acetylene [Ethylene] 74-86-2 10,000
Bromotrifluorethylene [Ethene, bromotrifluoro-] 598-73-2 10,000
1,3-Butadiene 106-99-0 10,000
Butane 106-97-8 10,000
1-Butene 106-98-9 10,000
2-Butene 107-01-7 10,000
Butene 25167-67-3 10,000
2-Butene-cis 590-18-1 10,000
2-Butene-trans [2-Butene, (E)] 624-64-6 10,000
Carbon oxysulfide [Carbon oxidesulfide (COS)] 463-58-1 10,000
Chlorine monoxide [Chlorine oxide] 7791-21-1 10,000
2-Chloropropylene [1-Propene, 2-chloro-] 557-98-2 10,000
1-Chloropropylene [1-Propene, 2-chloro-] 590-21-6 10,000
Cyanogen [Ethanedinitrile] 460-19-5 10,000
Dichlorosilane [Silane, dicloro-] 4109-96-0 10,000
Difluoroethane [Ethane, 1,1-difluoro-] 75-37-6 10,000
Dimethylamine [Methanamine, N=methyl-] 124-40-3 10,000
2,2-Dimethylpropane [Propane, 2-2-dimethyl-] 463-82-1 10,000
Ethane 74-84-0 10,000
Ethyl acetylene [1-Butyne] 107-00-6 10,000
Ethylamine [Ethanamine] 75-04-7 10,000
Ethyl chloride [Ethane, chloro-] 75-00-3 10,000
Ethylene [Ethene] 74-85-1 10,000
Ethyl ether [Ethane, 1,1'-oxybis-] 60-29-7 10,000
Ethyl mercaptan [Ethanethiol] 75-08-1 10,000
Ethyl nitrite [Nitrous acid, ethyl ester] 109-95-5 10,000
Hydrogen 333-74-0 10,000
Isobutane [Propane, 2-methyl] 75-28-5 10,000
Isopentane [Butane, 2-methyl-] 78-78-4 10,000
Isoprene [1,3-Butadiene, 2-methyl-] 78-79-5 10,000
Isopropylamine [2-Propanamine] 75-31-0 10,000
Isopropyl chloride [Propane, 2-chloro-] 75-29-6 10,000
Methane 74-82-8 10,000
Methylamine [Methanamine] 74-89-5 10,000
3-Methyl-1-butene 563-45-1 10,000
2-Methyl-1-butene 563-46-2 10,000
Methyl ether [Methane, oxybis-] 115-10-6 10,000
Methyl formate [Formic acid, methyl ester] 107-31-3 10,000
2-Methylpropene [1-Propene, 2-methyl-] 115-11-7 10,000
1,3-Pentadiene 504-60-9 10,000
Pentane 109-66-0 10,000
1-Pentene 109-67-1 10,000
2-Pentene, (E)- 646-04-8 10,000
2-Pentene, (Z)- 627-20-3 10,000
Propadiene [1,2-Propadiene] 463-49-0 10,000
Propane 74-98-6 10,000
Propylene [1-Propene] 115-07-1 10,000
Propyne [1-Propyne] 74-99-7 10,000
Silane 7803-62-5 10,000
Tetrafluoroethylene [Ethene, tetrafluoro-] 116-14-3 10,000
Tetramethylsilane [Silane, tetramethyl-] 75-76-3 10,000
Trichlorosilane[Silane, trichloro-] 10025-78-2 10,000
Trifluorochloroethylene [Ethene, chlorotrifluoro-] 79-38-9 10,000
Trimethylamine [Methanamine, N,N-dimethyl-] 75-50-3 10,000
Vinyl acetylene [1-Buten-3-yne] 689-97-4 10,000
Vinyl chloride [Ethene, chloro-] 75-01-4 10,000
Vinyl ethyl ether [Ethene, ethoxy-] 109-92-2 10,000
Vinyl fluoride [Ethene, fluoro-] 75-02-5 10,000
Vinylidene chloride [Ethene, 1,1-dichloro-] 75-35-4 10,000
Vinylidene fluoride [Ethene, 1,1-difluoro-] 75-38-7 10,000
Vinyl methyl ether [Ethene, methoxy-] 107-25-5 10,000

 

WHO TO CALL FOR HELP

Through each state in the Northwest, non-regulatory assistance is available for small businesses with air quality questions. The purpose of these programs is to:

• explain the air quality rules and recommend ways to comply;
• provide free, on-site technical assistance visits;
• help businesses estimate their air pollution emissions;
• refer businesses to needed resources; and
• provide information on potential sources of financing for compliance requirements.

For more information and free referrals, contact PPRC.


Produced by the Pacific Northwest Pollution Prevention Resource Center, 513 First Ave. West, Seattle, WA 98119
phone: 206-352-2050, fax: 206-352-2049, e-mail: office@pprc.org, WWW address: http://www.pprc.org

A joint project of the Small Business Assistance Programs in Alaska, Idaho, Oregon and Washington and funded by a grant from the U.S. Environmental Protection Agency.

This fact sheet is intended for general reference only; it is not a complete statement of the technical or legal requirements associated with this regulation.