Risk Management Plan Training

trainingWhy Is Risk Management Plan Training Necessary?

The Clean Air Act Amendment of 1990, Section 112(r), required the EPA to issue regulations and guidance to prevent accidents and releases at facilities producing, handling, processing, distributing, or storing certain chemicals. The Chemical Accident Prevention Provisions of Section 112(r) require these facilities to develop, implement and sustain a risk management plan (RMP).

Per the RMP rule, the owner or operator of each facility shall ensure each employee presently involved in operating a process, and each employee before being involved in operating a new process, shall be trained in an overview of the process and in the operating procedures. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks. In addition, “refresher training shall be provided at least every three years, and more if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process.”

How We Help With RMP Training

Cognascents provides a general RMP awareness training workshop to all employees regardless of whether they are an operator or not. Cognascents also helps clients develop and implement facility-specific training focused on achieving compliance with the above RMP rule requirements.

RMP Training

Cognascents offers RMP awareness training to anyone wanting to become more familiar with the history, background, requirements, and implementation approaches to the RMP rule. Cognascents provides a general overview of the following elements:

  • History of the RMP Rule
  • Definitions
  • Applicability
  • General requirements
  • Hazard assessment requirements
    1. Offsite consequence analysis parameters
    2. Worst-case release scenario analysis
    3. Alternative release scenario analysis
    4. Defining offsite impacts
    5. Five-year accident history
  • Prevention program requirements
    1. Threshold determination
    2. List of substances
  • Emergency response requirements
  • Regulated substances for accidental release prevention
    1. Threshold determination
    2. List of substances
  • Risk management plan requirements
  • Other requirements
    1. Recordkeeping
    2. Availability of information to the public

Facility-Specific RMP Training

Cognascents also helps clients develop and implement facility-specific RMP training. This training focuses on achieving and sustaining compliance with the RMP mandate. We tailor RMP facility-specific training to site-specific operating procedures and pair it with competency assessment tools for new employees and employees receiving refresher training.

At a minimum the RMP training will address the following:

  • Process overview
  • Safety and health hazards
  • Initial startup
  • Normal operations
  • Temporary operations
  • Emergency shutdown and operations
  • Normal shutdown
  • Startup following a normal emergency shutdown or a major change that requires a hazard review
  • Consequences of deviations and steps required to correct or avoid deviations
  • Equipment inspections

Cognascents has worked with many major oil, gas, and chemical corporations to develop training modules or to update existing training modules after a major design change. We have also worked with small companies to create training modules for processes that have grown in the last decade and are now covered by RMP.

Contact us to help you plan and price your next RMP training effort.