Use of an ISO 14000 Option in Implementing EPA's Rule on Risk Management Programs for Chemical Accidental Release Prevention

EPA's rule of Risk Management Programs for Chemical Accidental Release Prevention applies to facilities that manufacture, process, use, store, or otherwise handle regulated substances at or above specified threshold quantities. EPA estimates that approximately 66,000 facilities nationwide will be regulated under the rule. This paper examines the use of a structured ISO 14000 mechanism as option‐regulated facilities could elect for implementation of the rule. Under the ISO 14000 option, facilities would commit to additional obligations regarding information disclosure, discussions with potentially affected publics, and timely correction of deficiencies noted in annual ISO 14000 audits of their compliance with the Risk Management Program they submit to the EPA under the rule. In return, facilities would be granted significant relief in regard to both EPA audit frequency and the penalties that might be applied for any items of noncompliance with the rule noted during the course of implementing agency reviews of the facility. The paper concludes with a discussion of the advantages and disadvantages of this option to potentially affected stakeholders.