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.
- Program 1 — If under a worst-case scenario a release would not produce any off-site impacts and the facility does not have a history of releases.
- Program 2 — Facilities that do not meet Program 1 or Program 3 criteria.
- Program 3 — Facilities with the SIC code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, and 2911, or those that are required to have a Process Safety Management Plan.
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).
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 | 110-00-9 | 5,000 |
| Hydrazine | 302-01-2 | 15,000 |
| Hydrochloric acid (conc 30% or greater) | 7647-01-0 | 15,000 |
| Hydrocyanic acid | 74-90-8 | 2,500 |
| 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)] | 10102-43-9 | 10,000 |
| 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] | 75-44-5 | 500 |
| Phosphine | 7803-51-2 | 5,000 |
| Phosphorus oxychloride [Phosphoryl chloride] | 10025-87-3 | 5,000 |
| Phosphorus trichloride [Phosphorous trichloride] | 7719-12-21 | 5,000 |
| Piperidine | 110-89-41 | 5,000 |
| Propionitrile [Propanenitrile] | 107-12-0 | 10,000 |
| Propyl chloroformate [Carbonochloridic acid, propylester] | 109-61-51 | 5,000 |
| 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 | 91-08-7 | 10,000 |
| 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 |
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 |
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.
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.