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Risk Management Program Quality Assurance Program Plan. David R. Taylor US EPA Region 9 Quality Assurance Office. Products and Services Covered by the New Quality Policy. Data and Information produced for public use Data and information produced for internal Agency activities

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risk management program quality assurance program plan

Risk Management Program Quality Assurance Program Plan

David R. Taylor

US EPA Region 9

Quality Assurance Office

products and services covered by the new quality policy
Products and Services Covered by the New Quality Policy
  • Data and Information produced for public use
  • Data and information produced for internal Agency activities
  • Products and services produced by organizations external to EPA for EPA use
cio 2106 scope
CIO 2106 Scope
  • Environmental Data and Technology
  • Environmental Information
  • Assessments
  • Reports
  • Peer Review
  • Scientific Research
  • Regulatory Development
  • Information Technology to support services that collect and provide access to data & information
slide4

R9's Quality System Umbrella

Quality System

Quality Management Plan

QAPrP

QAPjP

SAP

SOP

quality assurance program plan
Quality Assurance Program Plan
  • Describes the QA System for an environmental program like the Clean Water Act, Clean Air Act
  • Program usually based on environmental regulations
  • Contains details like a QA Project Plan, but at a organization wide or program level
risk management program
Risk Management Program

Organizations Using, Storing or Transporting Hazardous Material must:

Comply with the General Duty Clause (CAA112(r)(1))

  • Identify Hazards
  • Design and maintain a safe facility
  • Follow codes, standards and other business practices
  • Minimize the consequences of a release
risk management program7
Risk Management Program

Organizations Using, Storing or Transporting Hazardous Material must:

  • Implement Chemical Accident Prevention

(CAA 112(r)(7))

    • Do a Hazard Assessment
    • Develop a Prevention Program
    • Establish an Emergency Response Program
  • Prepare a Risk Management Plans
slide8

Risk Management Program Federal Regulations

EPCRA - Emergency Planning and Community Right-to-Know Act (aka SARA Title III) Sections 302-312

CERCLA - Comprehensive Environmental Response, Compensation and Liability Act, Section 103

CAA 112(r) - Clean Air Act Section 112(r)(7), Chemical Accident Prevention Provisions and Risk Management Plans; and Section 112(r)(1) General Duty Clause (1990)

r9 risk management program issues
R9 Risk Management ProgramIssues
  • Hawaii Inspector needed Federal credential
  • No QA Documentation (except R9 QMP)
  • No QA Guidance available
  • Not an Environmental Data Collection Activity, but
  • Environmental Information collected
risk management plan
Risk Management Plan
  • Summarizes key elements of a Facility’s Risk Management Program
  • Submitted to the U.S. EPA and put in the Central Data Exchange (CDX)
  • Contains certification of accuracy and completeness
  • Contains a brief “Executive Summary”
  • Available to the public at “Reading Rooms”
  • Companion Emergency Response Plans available to EPA upon EPA request
rmp quality system
RMP Quality System
  • Review of Risk Management Plans based on National Guidance ensures consistency
  • Training and Certification
  • Audits
  • Administrative and Enforcement Action
training and certification
Training and Certification
  • Basic Inspector Training
    • Federal Inspection Credential
  • Risk Management Program Training
  • Confidential Business Information Training
risk management program audits
Risk Management Program Audits

Follow one of several checklists:

  • Program Level 1, 2 or 3 Checklist
  • Audit Checklist from “Guidance for Auditing Risk Management Plans/Programs under Clean Air Act Section 112(r)”
  • EPCRA/CERCLA Inspection Checklist for R9
rmp audits
RMP Audits
  • Has facility planned satisfactorily for incidents and releases?
  • Is it implementing the RMP as described?
  • Does plan cover all chemicals and processes subject to CAA112(r)(1) (GDC) or CAA112(r)(7) (ARR)
  • Does facility meet Mechanical Integrity, Process Safety and Emergency Response Requirements?
slide16

Off

Shut-off valve

conclusions
Conclusions
  • New Quality Policy will require flexibility
  • Existing systems must be respected
  • New approaches will be required by the QA Community
  • Documentation is key