How Much Risk Management Planning Was There?
There have been questions as to rules and regulations covering the hydroxylamine at the plant with regard to the surrounding community. Hydroxylamine is listed in 29CFR1910.119 (PSM) Appendix A “List of Highly Hasardous Chemicals, Toxics, and Reactives”, with a “Threshold Quantity for Coverage Under the Standard” of 2,500 pounds. The charge tank in which the explosion occurred was estimated to contain 750 pounds of hydroxylamine. The total amount present in the at the time of the explosion is uncertain. OSHA, PSM, and EPA OSHA and EPA lists are used by companies to determine their need for a Risk Management Plan (RMP). RMPs are studies, required by law to determine what risk stored or process chemicals pose to the surrounding community in the event of an unintentional release. Hydroxylamine is also on the EPAs Toxic Substances Control Act(TSCA) list and is classified as a mutagen. Materials on the TSCA list are regulated in terms of storage, handling and disposal. It must be understood
