PPSS – 27e The Case for Voluntary Third Party Risk Management Program Audits James C. Belke United States Environmental Protection Agency Chemical Emergency Preparedness and Prevention Office

In the preamble to the Risk Management Program regulations (40 CFR Part 68), EPA endorses the concept of offering sources the option of using third parties to assist owner/operators in meeting their obligations under the rule. EPA recognizes that any third party proposal must: not weaken the compliance responsibilities of source owner/operators, offer cost savings and benefits to the industry, community, and implementing agencies that significantly exceed the cost of implementing the qualified third party approach, lead to a net increase in process safety, particularly for smaller, less technically sophisticated sources, and promote cost-effective agency prioritization of implementing agency oversight resources. EPA is considering a voluntary program to offer regulated sources the option of using qualified third parties to audit RMP compliance. The decision to participate in the program or not would be completely at the discretion of the regulated source. To encourage participation in the program, EPA would offer regulatory incentives to participating facilities. In certain cases, a financial incentive may also exist through the use of insurance companies acting as third party auditors. EPA believes that this program will benefit participating facilities, surrounding communities, auditors, and RMP implementing agencies, and eventually lead to stronger and more uniform RMP compliance nationwide, with minimal costs. This paper will explain the proposed program, including the results of a pilot experiment, regulatory changes needed to support a national program, expected benefits of the program to industry, communities, auditors and implementing agencies, and the basic steps of program implementation.