Risk Management Plan Data Elements

Executive Summary

EXECUTIVE SUMMARY: As specified in §68.155, the owner or operator must provide an executive summary in the RMP. The executive summary should be brief and concise, no more than four pages in length for sources with one or two regulated substances. Your executive summary should include descriptions of:

1. The accidental release prevention and emergency response policies at the stationary source.
2. The stationary source and regulated substances handled. This information may be presented in a paragraph or as bullets. The information should include the following:
   • Primary activities (e.g., manufacturer of polyethylene, pulp mill, chlorine wholesaler);
   • Use of regulated substances (e.g., chlorine used to produce bleach, treat wastewater, repackage for sale);
   • Quantities handled or stored.
3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. The information should include the following:
   • The scenario (e.g., failure of the storage tank containing 40,000 pounds of chlorine, storage quantity limited to 60 percent of tank's capacity by company procedures; 10 minute release);
   • Distance to endpoint (e.g., under worst-case weather, the substance could travel x miles before dispersing enough to no longer pose a hazard to the public).
4. The general accidental release prevention program and chemical-specific prevention steps. For example, you may state that you are in compliance with the OSHA PSM rule and this rule. You may want to highlight general or specific steps that you believe are key to your prevention program. These steps may be either technological (e.g., backup systems) or procedural/managerial (e.g., improved maintenance or training).
5. The five-year accident history. This should be a summary (e.g., we have had five accidental releases of chlorine in the past five years; the largest release was 1500 pounds. No one offsite was injured, but several houses were evacuated as a precautionary measure during the 10/25/95 and 5/1/96 releases). Do not present the information in a table format.
6. The emergency response program (e.g., source has an emergency response plan, which has been coordinated with the community plan. The source hazmat team has conducted joint training and drills with the local fire department. Mention any public notification and alert systems).
7. Planned changes to improve safety.

Return to Index