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Learn the Issues
Science & Technology
Laws & Regulations
Risk Management Program
Risk Management Program
Applicability/General Duty Clause
Definition of fuel
RMP Contractor Related Requirements
NFPA 4 Criteria
Aggregating a substance located in multiple processes
Are agricultural facilities subject to the risk management program requirements?
Determining thresholds for different chemicals in interconnected vessels
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Determining frequency of coordination activities
Remote coordination with local authorities
Types of Information Relevant for Response Planning
Who must develop an emergency response program
Are exercises required as a part of the emergency response program requirements under 40 CFR Part 68, Subpart E?
Five - Year Accident History
Program 1 five-year accident history and hazard assessment differences
Five-year accident history for non-gas releases
Accidental releases from non-covered processes
Are releases under prior ownership included in the five-year accident history?
Do I have to report accidents that resulted in medical treatment?
Differences in accident history between Program 1 eligibility and the hazard assessment
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Offsite Consequence Analysis (OCA)
Ammonia (concentration 20% or greater) and ammonia (anhydrous) alternative release scenarios
Worst-case “quantity released” reporting for a mixture
Are mechanical controls considered administrative controls
Worst-case release scenario for separate, interconnected vessels
Identification of industrial buildings, commercial buildings, and recreational areas
When to Revise OCA
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Time Frame to Submit RMP Emergency Contact Information Changes
CFAT Impacts on EPCRA and RMP
Vulnerable zone determination
Obtaining an RMP ID number
RMP self-paced training courses
Accessing RMP data
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Plan Preparation and Submission
New owner using existing RMP
Requesting RMP*submit authorization code
RMP*esubmit preparer access
No Procedure for Requesting RMP Five-Year Review Extension
RMP guidance materials
Certification Statement for correction
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Hot Work permit procedures and date
Does compliance under OSHA's PSM demonstrate compliance with the risk management program?
Does a five-year update satisfy the requirement to conduct a compliance audit?
What constitutes a revision of the PHA?
Applicability of compliance audit provisions to emergency response programs
Applicability of compliance audit provisions to non-prevention program elements
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Certifying RMP process at higher program level
Hot Work permit review date
Hot Work Definition and Requirements
Applicability of program levels and prevention program requirements for co-located vessels
Are all covered processes subject to identical risk management program requirements?
Are evacuations and sheltering-in-place considered for Program 1 eligibility?
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Minimum / Maximum Distance to Endpoint
Different distances to toxic endpoints with different versions of RMP*Comp
Distance to endpoint calculations used by RMP*Comp
Local meteorological data for alternative release scenarios
Different results using ALOHA and RMP*Comp
Redoing calculations if RMP*Comp is updated
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