The Chemical Clean-Up: EPA Proposes Update to Accidental Release Prevention Checklist

Never before in history have consumers been so acutely aware of the chemicals in our everyday, household products. With momentum building in the demand for chemical disclosure and regulation in the marketplace, along with congressional and presidential support, the face of many of familiar products may be changing under the freshly revised Toxic Substances Chemical Act (TSCA).

It seems the rest of the chemical-regulatory front is also due for an update. The Accidental Release Prevention (ARP) requirements checklist is an EPA risk management program that covers statutes and regulations preventing the accidental release of air contaminants that might produce catastrophic effects.

This set of 1996 issued regulations comes from a sub-section of the 1990 Clean Air Act. Below is a run-down of what will remain unchanged and what the EPA hopes to update.

Unchanged checklist

  • Regulates specific substances, including 77 toxics and 63 flammables. Each substance has one or more threshold quantities that trigger compliance responsibilities.
  • Regulates sources of those substances, based on an interconnected process with a threshold quantity of one or more regulated substances. EPA assigns them to risk-based “programs” –
  • Program 1 contains low-risk sources, Program 3 are sources in industrial categories generally deemed high risk and Program 2 sources are those not in 1 or 3.
  • Define a risk management plan.
  • Regulated sources are responsible for periodic and event-related updates.

Want to read the full requirements? Visit Specialty Technical Publishers’ article for more details.

Proposed checklist changes

  • Administration changes: Make various technical corrections
  • Expand public information: Require all facilities to provide basic information to the public through easily accessible means, such as a facility website or public library.
  • Enhance emergency response requirements for Program 2 and 3 facilities.
  • Enhance hazard review: Require independent third-party compliance audit after release from Program 2 or 3, owners or operators of facilities with Program 3 regulated processes in NAICS codes 322 (chemical manufacturing), 324 (petroleum and coal products manufacturing), and 325 (paper manufacturing) would be required to conduct a safer technology and alternatives analysis.

The Proposed timeline for new / revised requirements are as follows:

  • One year – comply with emergency response coordination activities
  • Three years – develop an emergency response program
  • Four years – comply with other new provisions
  • Five years – correct or resubmit program to reflect new and revised data elements.

The proposal was published in the Federal Register on March 14, 2016. Comments were due by May 13. So far only minor concerns have been received, which means it looks like another promising update for EHS gurus.

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  • TSCA Applications
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  • TSCA12b: enables US exporters to submit TSCA Export Notifications to the US EPA. Search for a specific chemical and find out what you need to do to export it within regulation.
  • Safety Data Sheet (SDS) System
  • Maintain up-to-date SDSs for all chemical products.
  • Leverage SDS data for annual regulatory reporting, i.g. Toxic Release Inventory (TRI).
    TRI System
  • Enables sites to upload data files generated by US EPA TRI-ME Reporting Software.
    Facilitates data mining through maintaining a data repository of uploaded data files.

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