The clean air act section 112(r) risk management plans: Compliance requirements and alternatives

Abstract

Section 112(r) of the Clean Air Act Amendments of 1990 included significant compliance provisions for facilities to manage chemical process risk. The regulation promulgated by EPA, commonly referred to as the “Risk Management Plan” rule, will require a substantial fiscal, experiential, and human resource investment for installations that are required to comply. Primarily, most military installations that have to comply will do so for water disinfection or propane storage. In addition to regulatory liability, Section 112(r) rules also have a significant public affairs and facility security aspect. This article reviews the regulation to point out compliance challenges and presents methods for reducing or eliminating the need to be subject to the rule by employing safer, smarter business practices.