Rothstein Associates Inc.

RISK MANAGEMENT PLANNING HANDBOOK:
A COMPREHENSIVE GUIDE TO HAZARD ASSESSMENT, ACCIDENTAL RELEASE
PREVENTION, CONSEQUENCE ANALYSIS AND GENERAL DUTY CLAUSE
COMPLIANCE
by A. Roger Greenway, QEP, CCM

“The newly updated and expanded Risk Management Planning Handbook: A Comprehensive
Guide to Hazard Assessment, Accidental Release Prevention, and Consequence Analysis,
2nd Edition, leads businesses that house more than 100 hazardous or toxic materials on-site
through the process of creating an effective risk management plan and provides them with a
thorough understanding of the requirements for everyday decision making.

“This new edition of the earlier bestseller includes three new chapters and one new appendix
that reflect the increased focus on Risk Management Plans (RMP) in the past four years.
Under RMP regulations, facilities must conduct compliance audits every three years and
report their findings to the EPA. The new Chapter 6 “Auditing Risk Management Plans”
provides an expanded examination of the audit process. Risk Management Planning
Handbook: A Comprehensive Guide to Hazard Assessment, Accidental Release Prevention,
and Consequence Analysis, 2nd Edition explains why audits should be done, how to plan an
audit, and who to include on an audit team. It also provides key recommendations and a
series of questions auditors ask, which readers can use as a checklist to gauge the quality of
their own facility’s compliance, risk management plan, and hazard prevention program.

“In the new “General Duty Clause” chapter, author Roger Greenway discusses the
year-2000-issued clause in detail and explains the EPA’s interpretations of this new element
of the RMP. He examines the clause’s requirements (identify hazards, design and maintain a
safety facility, and thereby minimize the consequences of accidental release) and explains
what they mean to facilities. In another new chapter, “Communicating with the Public,”
Greenway addresses the importance and legal obligation of facilities to inform the public of
the potential releases. In this chapter, Greenway also explains the EPA- and FBI-inspired
Chemical Safety Information, Site Security and Fuels Regulatory Relief Act which was
created in 1999 to limit the amount of hazardous-release-impact information a facility can
make public through the Internet in an attempt to eliminate these facilities from being used as
potential targets for terrorist activities.

“Other changes that Risk Management Planning Handbook: A Comprehensive Guide to
Hazard Assessment, Accidental Release Prevention, and Consequence Analysis, 2nd
Edition addresses include EPA’s decision to adopt new consequence analysis modeling
practices, revise the list of regulated substances and thresholds for accidental release
prevention, and change the designation of regulated facilities from Standard Industrial
Classification (SIC) codes to North American Industrial Classification System Codes
(NAICS).

“Risk Management Planning Handbook: A Comprehensive Guide to Hazard Assessment,
Accidental Release Prevention, and Consequence Analysis, 2nd Edition includes a
section-by-section analysis of the RMP standard as well as multiple charts, tables, and
figures. The new Appendix E contains a variety of sample RMP forms and guidance, including
all nine sections of a RMP form, an Electronic Waiver Form, sample certification letters, a
Confidential Business Information Substantiation Form, state and regional contact
information, and a list of the new 3-digit NAICS Codes.

“From determining the rule’s effect on a company to creating a plan and incorporating that
plan with other compliance requirements, Greenway guides readers with comprehensive and
easy-to-use information. He offers specific, cost-effective recommendations on how to set-up
and carry-out risk management programs, how to identify worst-case emissions using “what
if” computer modeling for potential accidental releases, how to minimize the potential of an
accidental release, and how to minimize its consequence should one occur.

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CONTENTS

1: Overview: The Risk Management Plan: What It Is and Why You Need One
2: Setting Up a Prevention Program
3: Organizing Process Safety Information
4: Determining Operating Procedures
5: Organizing an Employee Information and Training Program
6: Auditing Risk Management Plans
7: Incident Investigations
8: Establishing an Emergency Response Plan
9: Handling Registration Procedures
10: Totaling the Costs
11: Avoiding Penalties
12: Coordinating with OSHA’s Process Safety Management Standard
13: Determining Program Levels of RMP
14: Choosing Analytical Methods
15: Selecting Inherently Safer Approaches
16: The General Duty Clause
17: Communicating with the Public
18: The RMP Standard: A Section-by-Section Analysis
19: Conclusions
Appendix A: EPCRA 302: List of Extremely Hazardous Substances
Appendix B: EPA’s Title III List of Lists
Appendix C: 40 CFR Part 68: Chemical Accident Prevention Provisions
Appendix D: NASA’s Lewis Safety Permit System
Appendix E: RMP Forms and Guidance Including EPA and State Contacts

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ABOUT THE AUTHOR

“A. Roger Greenway is a principal of RTP Environmental Associates, Inc., a national
environmental consulting firm specializing in air quality, asbestos, and other environmental
areas. He is a Qualified Environmental Professional and a Certified Consulting Meteorologist
with more than 29 years of experience in air pollution and risk management planning and
analysis. He has prepared RACT analyses, risk management plans, and Title V operating
permits for a large number of industrial facilities and is a nationally recognized expert in air
pollution consulting, specializing in permitting, modeling, monitoring, and risk assessment.”

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2004, 338 pages. Order #DR372.
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