environmental Strategist, between the lines: Do you have Agricultural client’s impacted by Risk Management Program Regulations (RMPR)? Are they aware they have to update their RMPR every five years to stay in compliance.
If you have agricultural clients that use, store, manufacture or handle the on-site movement of 10,000 pounds or more of anhydrous ammonia they may be impacted by RMPR.
It does not send a positive message to customers when they read about a business in the paper for receiving an environmental fine.
ERMI Risk Management Strategy: Attached you will find an ERMI Environmental Risk Assessment (ERA) you can share with your agricultural insured’s. The ERA is designed to get you and your insured on the same page about the environmental exposures impacting their operations. Through this process your insured can make an informed decision if environmental liability insurance can add value to their business
model.
Risk Management Rules and Farms
From: Andy Soos, ENN
Published February 28, 2011 08:00 AM
ADI Agronomy, Inc., which owns a group of farm supply facilities in southeast Missouri and northeast Arkansas, has agreed to pay a $54,922 civil penalty to the United States for chemical Risk Management Program violations at its Ag Distributors retail facility at Kennett, Mo., which sells liquid fertilizer made with anhydrous ammonia. Specifically, Ag Distributors failed to establish and implement maintenance procedures to ensure the ongoing integrity of its anhydrous ammonia process equipment, and failed to document that the equipment complied with recognized and generally accepted good engineering practices, among other violations.
Anhydrous ammonia is one of the most efficient and widely used sources of nitrogen for plant growth. Anhydrous ammonia is corrosive, and exposure to it may result in chemical-type burns to skin, eyes and lungs.
The Ag Distributors facility in Kennett is subject to the Risk Management Program regulations because it uses, stores, manufactures or handles the on-site movement of 10,000 pounds or more of anhydrous ammonia in its fertilizer production process.
Facilities like Ag Distributors that mix or blend fertilizers using anhydrous ammonia, but which do not sell anhydrous ammonia directly to farmers, must implement the most stringent type of Risk Management Program. Risk Management regulations are intended to help prevent accidental releases of harmful chemicals, and help local emergency responders prepare for and respond to chemical accidents. Failure to have an adequate Risk Management Program and Plan can compromise a facility’s ability to prevent
releases and minimize the impact of releases that do occur.
These are not the first agricultural product firms hit with these fines. In October 2009, EPA discovered that AG Link, Colfax and their eight facilities located at Almira, Davenport, Edwall, Coulee City, Reardan, Colfax, Wilbur, and Steptoe, Washington failed to update their risk management practices at least every five years as required by the CAA. The facilities store more than 10,000 pounds of anhydrous ammonia, which exceeds the threshold quantity that triggers federal planning requirements.
In 2007 the following firms were fined. Under this effort, EPA took legal action against the following facilities throughout New England: – A.T. Wall Company, Inc. (Warwick, R.I.)- Danbury Water Pollution Control Plant (Danbury, Conn.)- Gold Medal Bagel Bakery, Inc. (West Haven, Conn.)- Mace Adhesives and Coatings Co., Inc. (Dudley, Mass.)- Northampton MA Wastewater Treatment Plant (Northampton, Mass.)- Shield Packaging Co., Inc. (Dudley, Mass.)- Stonyfield Farm, Inc. (Londonderry, N.H.) – Webster Wastewater Treatment Plant (Webster, Mass.) The bulk chemicals used and stored at these facilities included anhydrous ammonia, toluene, isobutene and chlorine. As a result of these cases, the facilities have agreed to correct the violations and pay penalties ranging from $300 to $3,650.
For further information: http://yosemite.epa.gov/opa/admpress.nsf/0/C52FA12AA069AA5F8525783F00662CA3