Risk Management Guide For Major Industrial Accid

New Edition
Reviewed and Enhanced
Adopted by the
Conseil pour la réduction des accidents industriels majeurs (CRAIM)
2002 Edition - PDF Version
1
Note
Note:
Certain substances or situations other than those identified and described in this guide may be
the source of significant risks.
It is the responsibility of each facility to guard against accidents and to report to its municipality
all risks that could have consequences off-site, even if these risks are not covered by the present
guide.
Legal Deposit – Bibliothèque nationale du Québec, 2002

Legal Deposit – National Library of Canada, 2002
ISBN 2-922820-04-1
2 Risk Management Guide for Major Industrial Accidents

Foreword
Foreword
T his risk analysis and management guide for major industrial accidents intended for munic-
ipalities and industry was developed by CRAIM (Council for Reducing Major Industrial Accidents/
Conseil pour la réduction des accidents industriels majeurs).
With a mission to foster the reduction of the frequency and severity of major industrial accidents
involving hazardous materials, CRAIM aims to improve the joint preparedness and response sta-
tus of municipalities and industry.
The primary objective of CRAIM is to promote the implementation of prevention, preparedness
and response (PPR) programs related to industrial risks in the province of Quebec, according to
recognized standards and norms.
A secondary objective is to plan and organize training activities corresponding to the needs and
the particular development dynamics of municipalities and industry.
This new edition of the CRAIM Guide has received the unconditional support of the Association
industrielle de l’est de Montréal (AIEM), the Canadian Chemical Producers’ Association (CCPA),
Gilles La Madeleine, president of the Association des chefs de services d’incendie du Québec,
and the Canadian Petroleum Products Institute (CPPI).
CRAIM wishes to acknowledge the following individuals, who, thanks to their knowledge and
experience, have enabled the publication of the risk analysis and management guide for major
industrial accidents intended for municipalities and industry.
Jean-Paul Lacoursière
Engineer and risk management specialist
Robert Reiss
Emergency responder
Environment Canada
Isabelle Beaudoin
Consultant for CRAIM
Madeleine Gaudreau
Director, Communication Services
City of Montréal-Est
Thérèse Drapeau (Chapter 7)
Environment Canada
Marcel Ricard (Chapter 7)
D’Aragon, Desbiens, Halde Associés
Ginette Joly (review)
Treasurer of CRAIM
Maria Schaffer (reviewed the English translation)
Joint Coordinating Committee of Montréal-Est
(Le comité mixte municipal-industriel de l’est de Montréal)
Translation by David Mitchell
Graphic design and computer graphics: Philippe Routier - infographyl@yahoo.ca
We would also like to thank several members of CRAIM for their support and comments.
Risk Management Guide for Major Industrial Accidents 3
Preface
Preface
M uch has happened since the first edition of the Guide in 1996. Risk management has
evolved and the community is seeing more and more the benefits. Numerous JCCs (Joint
Coordinating Committees) have come into existence and the participation of citizens on these
committees has not stopped rising. For its parts, industry is showing more openness and every-
one is working together to reach the same objective: reducing the frequency and seriousness of
accidents involving hazardous materials as well as improving the joint preparedness and
response state of municipalities and industries.
The November 2001 edition of the Guide was so well received that it is already out of stock.
We are taking advantage of this new printing to improve this guide once again.
The most important revision concerns the List of Hazardous Materials and the reworking of
Annex 3. Robert Reiss, with the assistance of Jean-Paul Lacoursière, has undertaken the review-
ing of the names taking into account international nomenclature and names generally used in
the America, whether found in the CANUTEC guide, the EPA regulations or even in the
Canadian Environmental Protection Act-1999. To make it easier to use, the List of Hazardous
Materials is now presented under 4 different formats thus allowing establishments to determine
more easily if a particular substance is found in the List. The formats are: a list by order of CRAIM
classification, a list by alphabetic order, a list by CAS number and finally a list by United Nations
(UN, numbers used in the CANUTEC guide).
Some threshold quantities have been modified following a review of the calculations based on
the methodology used by the EPA. A description of the methodology is presented at the begin-
ning of Annex 3.
As for Annex 4, it now includes the bibliography of the original MIACC document published in
1994. Annex 5 more faithfully reflects its source document, namely the EPA’s “General
Guidance for Risk Management Programs.” Lastly, the names of the hazardous materials of the
tables in Annex 6 have been translated and written according to the same nomenclature used
of the list of Annex3.
We would like to thank all those who have, directly or indirectly, helped us in preparing this new
edition. Particular thanks go out to Robert Reiss, Jean-Paul Lacoursière, Thérèse Drapeau, Marla
Sheffer, and Claude Rivet.
Montréal, June 2002
Yves Dubeau
CRAIM’s president

UNEP's APELL programme
The fifth edition of “the Risk Management Guide for Major Industrial Accidents” prepared by
the Conseil pour la réduction des accidents industriels majeurs (CRAIM) respects the principles
of the APELL (Awareness and Preparedness for Emergencies at the Local Level) programme. The
contents of the Risk Management Guide are updated regularly in order to take into account any
new scientific developments in the field of risk management.
CRAIM agrees with APELL Programme objectives set out by the United Nations Environment
Programme (UNEP).

The APELL Programme (Awareness and Preparedness for Emergencies at Local Level) has been
developed by UNEP to minimise the occurrence and harmful effects of technological accidents
and emergencies by raising awareness of local communities and by improving the communica-
tion among parties. It provides a well-structured, detailed process for developing a co-ordinat-
ed, integrated and well-functioning emergency response plan for local communities.
APELL is a tool for bringing people together to allow effective communication about risks and
emergency response. The communication in turn leads to an action agenda.
The process of dialogue, as recommended in the APELL procedure, should help to:
• reduce risk;
• améliorer l’efficacité de la réaction aux accidents,
• allow people to react appropriately during emergencies.
For further information about the APELL Programme, see:
http://www.uneptie.org/apell

Craim Mission
Craim Mission Statement
Our Vision
The CRAIM vision (Conseil pour la réduction des accidents industriels majeurs) is to facilitate the
development of a concerted approach to the management of industrial risks involving hazadous
materials.
Our mission
The CRAIM mission is to offer a common place where all parties involved in the management
of industrial risks can meet to exchange knowledge to reduce the frequency and severity of
industrial accidents involving hazardous materials.
Our objectives
The main objective of CRAIM is to create a group of experts (municipal, industrial and govern-
mental) in the field of industrial risks management to develop standards management tools for
responders.
This group will also provide expert advice to various levels of governments ito assist in the cre-
ation of effective and realistic regulations in the field of industrial risks management.
Finally, CRAIM prepares and offers training programs corresponding to the needs and the par-
ticular development dynamics of municipalities and industries in the industrial risk field.

Table of Contents
Table of Contents
Note . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
UNEP’s APELL Programme . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6
Craim Mission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
Chapters:
Chapter 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
Chapter 2 Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
Chapter 3 Analysis of the Risk of Major Industrial Accidents . . . . . . . . . . . . . . . . . .19
Chapter 4 Control of Risks and Actions/Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . .35
Chapter 5 Residual Risk/Vulnerability Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41
Chapter 6 Development of an Emergency Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .47
Chapter 7 Risk Communication and
Emergency Situation Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51
Chapter 8 Evaluating the Goal of the Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75
Annexes:
Annex 1 Sample Letter and Instructions to Companies . . . . . . . . . . . . . . . . . . . . .107
Annex 2 Origin of Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111
Annex 3 List of Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117
Annex 4 Guiding Principles for Joint Municipal and Industrial
Emergency Preparedness: Improving Community Safety . . . . . . . . . . .153
Annex 5 Excerpts from the EPA Document “General Risk Guidance
Management Programs Guidance” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .167
Annex 6 Calculation Method for the Worst-case Scenario:
Excerpts from the EPA Document “Risk Management Program
Guidance for Offsite Consequence Analysis” . . . . . . . . . . . . . . . . . . . . . .261
Annex 7 Determining Alternative Release Scenarios:
Excerpts from the EPA Document “Risk Management Program
Guidance for Offsite Consequence Analysis” . . . . . . . . . . . . . . . . . . . . . .327
Annex 8 Risk Management Plan Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .373
Annex 9 Selected Books and Software . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .385
Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .389
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .397
Membership Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .401

Introduction
1
Chapter
11
Chapter 1
T he goal of this guide is to protect public health and life, as well as the quality of
the environment, in the event of a major industrial accident, by providing decision-
makers with a framework for establishing a complete and systematic prevention,
emergency measures and communication program.
This approach will allow the development of positive communication, based on current data,
between establishments, municipal emergency services and citizens. It is intended to create a
partnership between industry, municipalities and citizens for the development of an effective
emergency measures prevention and maintenance program.
Annex 5 is based on the Risk Management Program (RMP) of the U.S. Environmental Protection
Agency (EPA). This annex, however, contains different elements, since the list of hazardous sub-
stances includes 38 more substances than the list of the RMP. As well, Annex 5 introduces con-
cepts of responsible management and the taking into account of meteorological conditions.
These supplemental elements have been added to underscore the following advisory: “It is the
responsibility of each facility to guard against accidents and to report to its municipality all risks
that could have consequences off-site, even if these risks are not covered by the present guide.”
Local or municipal authorities and industries are responsible for assessing and managing risks
associated with activities involving hazardous materials. Industries must put in place and main-
tain a system for managing risks to prevent accidents. Meanwhile, despite prevention efforts,
the potential for an accident will always exist. It is for this reason that municipalities and indus-
tries must be prepared to respond in an effective and coordinated manner during accidents
involving hazardous materials. This type of preparedness can take place only in municipalities
that are aware of their vulnerability, where public protection and the environment combine with
the management of industrial risks. The public expects industries and municipalities to imple-
ment effective prevention measures and to be prepared to respond in different types of situa-
tions.
This type of joint process for accident prevention and emergency measures preparedness carries
with it numerous benefits. It:
• ensures the safety of the public, responders and workers;
• reduces damage to the environment and to property;
• decreases the response time during municipal, industrial and governmental interventions; and
• makes municipalities, industries and the public aware of the risks of major industrial acci-
dents.
The production, storage and use of an ever-increasing quantity of hazardous materials pose for
industry the risk of a significant increase in major accidents. To control these risks and protect
the population, workers and the environment, it is critical to implement in a systematic way a
set of well-defined measures.
The Council for Reducing Major Industrial Accidents (CRAIM) supports projects that aim to fos-
ter the implementation of an integrated risk management program in order to prevent major
industrial accidents and to reduce their consequences.

Chapter 1
Figure 1
Global Risk Management Process
Risk Management
(CSA - Q 850)
Prevention Implementation
Communication
(Chapter 2)
Analysis of Risks
Determination
• Emergency of Risks
Planning (Chapter 3) Evaluation of Risks
• Training Preparation
• Exercises Chapter 6
Risks Control
(Chapter 4)
Incident
• Response Actions/Monitoring
• Restoration (Chapter 4)
Residual Risks
Vulnerability Study
(Chapter 5)
Review

Implementation
2
Chapter
15
Chapter 2
R isk management in the context that concerns us here calls for a genuine change of
approach. This new approach contains three facets: prevention, implementation of emergency
measures (preparedness) and sharing information with citizens who are subject to risk. A new
approach involves the evolution of individuals and groups toward the sharing of common val-
ues. For this evolution to have a chance at success, a fertile milieu is required. The Joint
Coordinating Committees (JCCs) have proven to be this fertile milieu, and as such represent the
recommended model. The Emergency Preparedness Department of the Government of Quebec
has committed resources to facilitate such a process.
However, establishments must implement their own prevention measures and emergency plans.
On the other hand, public administrations (especially municipalities) are obligated to ensure that
the establishment has fulfilled its obligations and that these same public administrations have
emergency plans in place to intervene effectively in case of accident.
Identifying the Issues

Municipalities and industry are responsible for the safety of citizens and the protection of the
environment in case of accident caused by human actions or a natural phenomenon. As well,
industry is equally concerned with the prevention of accidents and the health and safety of
workers on work premises. Municipalities and industry must have their own emergency meas-
ures preparedness programs; however, the two types of programs are not necessarily comple-
mentary—hence the great importance of a joint approach (MIACC 1993).
General Objective
• Prevent major industrial accidents, reduce the consequences for the population and the
environment, and improve the preparedness status and the response capability of the estab-
lishments.
Specific Objectives
• Ensure that the hazards are identified by the establishments.
• Ensure that sensitive areas identified by the concerned authorities are taken into account.
• Implement a worst-case method to:
∆ identify the target establishments;
∆ gather information on the hazardous materials that these establishments use, produce
and store; and
∆ evaluate the zones of impact of the target establishments on the population, the sensi-
tive areas and the impact on workers.
• Ensure that the target establishments—for which the impacts of potential emissions go
beyond the site—carry out the following steps:
∆ conduct a risk study of facilities having impact zones that affect the population and
sensitive areas, by developing (plausible) alternative accident scenarios that take into
account mitigation measures and the process safety management programs (preven-
tion) in place;
∆ implement a control or risk mitigation program (process safety management program);

Chapter 2
∆ implement an emergency plan conforming with the CAN/CSA-Z731-95 and NFPA

1600 standards by taking into account the residual risks posed by the establishment;
∆ present the emergency plan to the JCC for review and comments and to the munici-
pality for approval; and
∆ list the emergency measures that the establishments and the municipalities have put in
place.
• Harmonize as needed the municipal and/or industrial emergency plans.
• Support the responders who have to communicate the pertinent information to the individ-
uals susceptible to being affected.
Implement a Joint Coordinating Committee (JCC)

The objective of this step is to organize a Joint Coordinating Committee (JCC) whose mandate
is to steer the risk management plan of the municipality.
Each municipality is responsible for promoting the municipal and industrial coordination of
emergency measures. In order to accomplish this coordination, a municipality and its industries
must first clear the groundwork for a JCC:
• by setting up a committee of representatives from the municipality and industries; or
• by adding industry representatives to the existing municipal committee.
The JCC should include representatives of concerned citizens residing in the municipality. The
JCC should also include governmental agencies and interest groups. Regardless of the makeup
of the committee, its members must firmly grasp the mandate of the committee and their
respective roles.
(See Annex 4 of this guide.)
The committee should be officially structured in a manner to exercise sufficient authority to:
• determine the risks to the population;
• gather and exchange pertinent information;
• harmonize the municipal and industrial emergency plans;
• identify and establish necessary communication networks, secure the required communica-
tion equipment and formulate the communication procedures;
• develop the approaches and the means to communicate with the public and the media;
• develop and administer joint training, exercise and emergency simulation programs; and
• draft mutual aid agreements.

Analysis of the Risk
of Major Industrial Accidents
3
Chapter
19
Chapter 3
T his chapter is based on the work of the JCC of Montréal-Est, following consultation with
citizens, municipal administrations, businesses and governmental agencies. Certain elements
have been added to facilitate understanding.
The analysis of the risk of major industrial accidents is the starting point of a risk management
approach. It should first be pointed out that the process in which the establishments are invit-
ed to participate is usually initiated by a JCC and that joining the process is voluntary.
Objectives
At this step, the objectives pursued by the JCC aim to:
• identify the hazards related to activities involving hazardous materials within its territory;
• assist risk generators in evaluating the consequences of major industrial accidents;
• encourage these risk generators to implement the required prevention activities;
• develop and test harmonized (municipality/industry) emergency response plans; and
• properly inform the community.
The process described in this chapter therefore aims, in the case of establishments at risk of
major industrial accidents, to implement a diligent and voluntary prevention program intended
to control or mitigate the consequences of the identified hazards.
A major industrial accident is defined here as an unexpected and sudden event involving haz-
ardous materials (release of toxic matter, explosion, thermal radiation) and having consequences
for the population and the environment outside the site of the establishment.
Method
The guide adopts an approach based on the RMP (Risk Management Program) method of the
EPA (U.S. Environmental Protection Agency), the organization responsible for enforcing the
American regulation that covers certain risk management aspects of major industrial accidents.
This regulation covers the identification of risks up to their communication to the public,
through the mandatory declaration of hazardous materials, spills occurring at companies and
emergency measures and process analysis plans.
The present guide does not claim, however, to provide the details of this method. Instead, it
reviews the basic rules and provides clarification. The user should refer to the EPA documents,
or to the authorities in his/her municipality, for more information. The references cited in this
guide are taken from the document “General Guidance for Risk Management Programs” (40
CFR Part 68), identified by EPA code 550-B-00-008, May 2000.
Note
Certain substances or situations other than those identified and described in this guide may be
the source of significant risks.
It is the responsibility of each facility to guard against accidents and to report to its municipality
all risks that could have consequences off-site, even if these risks are not covered by the present
guide.

Chapter 3
Approach for the Analysis of Risks

of Major Industrial Accidents
Step 1 – Establishments at Potential Risk

The JCC draws up a list of establishments that, given the nature of their operations, can pose
the risk of a major industrial accident.
The list should include those establishments that have the potential to emit hazardous materi-
als that can affect the population and sensitive areas following a fire or chemical reaction.
Table 1 summarizes some of the types of industrial activities as well as the hazardous materials
likely to be found.
Step 2 – Target Establishments

The municipality sends, to all establishments identified in step 1, a letter requesting them to
identify, with the help of the enclosed list of hazardous materials, the materials they are holding
in quantities greater than threshold quantity and, if necessary, to record the maximum quantity
that can be held.
An example of this letter and the list of hazardous materials are included in Annexes 1 and 3,
respectively. The origin of the hazardous materials list used for the analysis is explained in
Annex 2.
In order to determine the quantity of hazardous material held by an establishment, the process
capacity is considered here as the maximum holding capacity.
According to the EPA definition, a process consists of: “Any activity involving a regulated sub-
stance, including any use, storage, manufacturing, handling, or on-site movement of such sub-
stances, or combination of these activities. For the purposes of this definition, any group of ves-
sels that are interconnected, or separate vessels that are located such that a regulated substance
could be involved in a potential release, shall be considered a single process.” [See Annex 5]
The establishment should take into account the particular regulations set out by the EPA, such
as, for example, the regulations concerning substances found in a mixture of aqueous or refrig-
erated solutions. [See Annex 5]
It is understood that this process does not take into account those hazardous materials held indi-
vidually in a quantity lower than the threshold quantity.
If an establishment holds a hazardous material appearing on the list, and for which the maxi-
mum inventory at any given moment exceeds the threshold quantity, this establishment must
be subject to the process for the management of risks of major industrial accidents and must
submit to step 3.

Chapter 3
TABLE 1
Examples of Establishments Likely
to Hold Hazardous Materials
LOCATIONS HAZARDOUS MATERIALS

AND OTHER SUBSTANCES
1. Large storage or combustible-processing

facilities
• Refinery and storage . . . . . . . . . . . . . . . . . . . . . . . . . . . .Gasoline, naphtha, hydrofluoric acid, propane, butane,
ethylene, propylene, mercaptan, liquefied natural gas and
other combustibles
• Intermediary storage . . . . . . . . . . . . . . . . . . . . . . . . . . . .Gasoline, diesel, propane, butane and other combustibles
• Service station . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Gasoline, diesel, propane
2. Transport of petroleum or gasoline

• Gas distribution centre . . . . . . . . . . . . . . . . . . . . . . . . . .Natural gas, propane
• Pipelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Natural gas, propane, butane, ethylene, ethane, methane,
kerosene, crude petroleum, chlorine, hydrogen, etc.
3. Large cooling facilities

• Food industry
(slaughterhouses, dairy products, fat,
fish and meat, breweries,
refrigerated warehouses, etc.) . . . . . . . . . . . . . . . . . . . .Ammonia
4. Food
• Spices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ethyl oxide
• Sugar industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Sulfur dioxide
• Flour processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Methyl bromide
• Extraction of vegetable
or animal oils and fats . . . . . . . . . . . . . . . . . . . . . . . . . . .Hexane
• Cocoa, chocolate and coffee industry . . . . . . . . . . . . .Hexane, ammonia
• Yeast . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Various solvents, ammonia
• Brewery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ammonia
• Distilleries, alcohol bottling . . . . . . . . . . . . . . . . . . . . . .Ethanol
5. Specific basic products

• Leather industry (tannery) . . . . . . . . . . . . . . . . . . . . . . .Acrolein, formic acid
• Wood distribution industry . . . . . . . . . . . . . . . . . . . . . . .Formaldehyde, impregnation agents
• Paper industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Chlorine, chlorine dioxide, sulfur dioxide,
ammonia
• Rubber industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Styrene, butadiene
• Glass industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrofluoric acid

Chapter 3
TABLE 1 (CONT.)
Examples of Establishments Likely to Hold Hazardous Materials

6. Metallurgic
and electronic industry
• Aluminum smelters . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrofluoric acid, oleum, chlorine
• Magnesium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrochloric acid, chlorine, hydrogen,
sulfur dioxide
• Gold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Carbon monoxide, nitric oxide
• Smelting furnaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Cyanides, sulfur dioxide
• Lead processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Lead compounds
• Surface preparation (plating) . . . . . . . . . . . . . . . . . . . .Acids, plating solutions, arsine, cyanides
• Copper refining . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Sulfuric acid, arsine, sulfur dioxide
• Pigments of titanium dioxide . . . . . . . . . . . . . . . . . . . . .Sulfuric acid, chlorine, titanium tetrachloride
• Electronic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Arsine, trimethylchlorosilane
7. Specific chemical products

• Fertilizer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ammonia, nitric acid, nitric oxide,
ammonium nitrate
• Synthetic resins . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ethylene oxide, propylene oxide, chlorine, acrylonitrile,
phosgene, isocyanates, formaldehyde, styrene
• Rubber . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Butadiene, styrene
• Plastics and other synthetic products . . . . . . . . . . . . . .Ethylene, propylene, vinyl chloride, acrylonitrile, chlorine,
toxic combustion products
• Paints and pigments . . . . . . . . . . . . . . . . . . . . . . . . . . . .Phosphine, various solvents
• Perfumes and essences . . . . . . . . . . . . . . . . . . . . . . . . . .Acids, solvents, toxic combustion products
• Synthetic products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Carbon sulfide, hydrogen sulfide
• Medications and other
pharmaceutical products . . . . . . . . . . . . . . . . . . . . . . . . .Chlorine, sulfur compounds, solvents, formic acid
• Detergents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Acids, bases, ethylene oxide
• Cleaning agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Acids, bases
• Linoleum products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Solvents, toxic combustion products
• Textiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Lye, dyes, solvents, formic acid
• Printing products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Solvents
• Photographic and cinematographic products . . . . . . .Nitrocellulose
• Fluorocarbons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrofluoric acid
8. Pesticides
• Production of raw materials . . . . . . . . . . . . . . . . . . . . .Phosgene, isocyanates, chlorine
• Bulk sale and storage . . . . . . . . . . . . . . . . . . . . . . . . . . . .Toxic powders and liquids, toxic combustion products,
ammonia
• Retail sale and storage . . . . . . . . . . . . . . . . . . . . . . . . . .Various substances, methyl bromide
• Smelting furnaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Cyanides, sulfur dioxide

Chapter 3
TABLE 1 (END)
Examples of Establishments Likely to Hold Hazardous Materials

9. Chemical products:
non-specific raw materials
• Inorganic products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Chlorine, ammonia, hydrochloric acid, sulfuric acid,
oleum, sulfur dioxide, chlorine dioxide
• Organic products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Acrylonitrile, phosgene, solvents
• Industrial gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrogen, solvents, phosgene
10. Explosives
• Production and storage of explosives . . . . . . . . . . . . . .Explosives, nitric acid, TNT, ANFO

• Storage of munitions . . . . . . . . . . . . . . . . . . . . . . . . . . .Munitions, TNT
• Manufacturing and sale of fireworks . . . . . . . . . . . . .Fireworks, pyrotechnic parts
• Others . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrogen peroxide, organic peroxides, ammonium
nitrate, sodium chlorate, etc.
11. Public areas and services
• Drinking water filtration plant . . . . . . . . . . . . . . . . . . . .Chlorine

• Sewage treatment plant . . . . . . . . . . . . . . . . . . . . . . . . .Chlorine, hydrogen peroxide
• Pool . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Chlorine
• Arena, rink . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ammonia
• Hospital . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Oxygen, gas and various solvents
12. Pipelines except those used

for fixed installations . . . . . . . . . . . . . . . . . . . . .Chlorine
13. Laundries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Chlorinated solvents
14. Centres for transferring,

processing and eliminating
hazardous materials . . . . . . . . . . . . . . . . . . . . . .Solvents, chlorinated solvents, cyanides
15. PVC industries . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrogen chloride, chlorine, phosgene, dioxins
16. Storage sites for

hazardous waste . . . . . . . . . . . . . . . . . . . . . . . . .Various chemical products
17. Storage of PCBs, tires,

various scraps (plastic) . . . . . . . . . . . . . . . . . . . .Toxic combustion products

Chapter 3
Step 3 – Analysis of the Accident Consequences

Worst-case Release Scenarios
Next, the target establishment in step 2 carries out an analysis of the consequences of an uncon-
trolled emission of the hazardous materials that it has declared, according to preestablished con-
ditions.
This consequence analysis aims to establish if an industrial accident involving hazardous materi-
als can have consequences outside the site of the target establishment. This analysis is conduct-
ed according to the method defined by the EPA for “worst-case release scenarios.” [See Annex
5]
The worst-case release scenario is the emission of the greatest quantity of a hazardous sub-
stance, held in the largest container, whose impact distance is the greatest.
Whether the hazardous materials consist of toxic or flammable substances, conditions are
preestablished to help understand the worst-case scenarios. These standard conditions concern
the meteorological conditions, the duration of the loss of containment, the quantities of the
product to consider, the physical conditions of the accident site, etc. [See Annex 5]
Methodology for Calculating the Consequences
• Substances listed by the EPA
The RMP (Risk Management Program) of the EPA applies to 140 listed substances (classes A and
B of Annex 3), of which 63 are toxic and 77 flammable.
The assessment of the consequences of worst-case release scenarios and alternative accident
scenarios is an important step of the RMP. Figure 2, “Process According to the RMP of the EPA,”
illustrates this approach.
The specific conditions related to the development of worst-case scenarios required by the RMP
are summarized in Table 2.
The conditions for calculating the worst-case scenario are predefined, especially the ambient
temperature, which is 25°C. Given that the substances from the EPA list are volatile (i.e., at
25°C), are in a gaseous phase or have a high vapour pressure, the worst-case scenario will usu-
ally give the maximum consequences at this temperature.
• Other substances listed by CRAIM
As is the case for the substances listed by the EPA, the assessment of the consequences of the
worst-case release scenarios and alternative accident scenarios of other substances listed by
CRAIM (classes C, D, E and F) will be carried out according to the approach illustrated by Figure
2, “Process According to the RMP of the EPA.”
Once again, the specific conditions related to the development of worst-case scenarios required
by the RMP are summarized in Table 2.
Taken into account here is the fact that most of the 35 other substances listed by CRAIM have
boiling points greater than 25°C. It follows from this that an assessment of the worst-case sce-
nario consequences at 25°C would present minimal consequences, which would then exclude
establishments having this process from the risk management procedure.
It is therefore wiser to evaluate the consequences of worst-case release scenarios by taking into
account the operating conditions of the equipment that contains the listed substances. In most
of these cases, these operating conditions are found in processes where the temperatures and
pressures are high, although the quantities of the listed substances are low. By proceeding in
this manner, the worst-case scenario will represent the most severe operating conditions, while
usually giving impact distances greater than those coming from storage equipment.

Chapter 3
Note:
The list of other substances listed by CRAIM includes explosive substances, an explosive and
reactive fuel substance that generates a toxic gas (sodium chlorate) and a substance (phospho-
rus) that generates toxic combustion products. These substances must be considered individu-
ally, and the data that allow for their analysis are complex and difficult to obtain.
The evaluation takes into account the passive mitigation measures only (for example: physical
shelters, diked areas for gases liquefied by refrigeration). Measures of an administrative nature,
such as stock limitations, are taken into account at this stage of the analysis.
The Number of Scenarios to Present
The analysis must evaluate for each target establishment a scenario for the impact of the emis-
sion of a toxic substance and a scenario for the impact of a flammable substance, if these two
types of substances are held in a quantity exceeding their threshold quantity.
The choice of the toxic substance to be analyzed should be made after evaluating the emission
that will have the largest impact radius, according to the product quantity, the conditions and
the emission site. The impact radius for toxic substances must take into account the protection
of the general public and allow persons present in the affected zone to be exposed to the prod-
uct for a period ranging from 30 to 60 minutes, without serious effects on their health.
The choice of the flammable substance will be made after evaluating the maximum distance at
which a superpressure of 6.9 kPa (1 psi—pound per square inch) will be felt following the explo-
sion of the greatest quantity of this substance, after it has been emitted in a vapour cloud.
The analyses conducted must also take into account the location of the hazardous substance in
relation to the proximity of the populations that could be affected. Therefore, if the accident has
an impact on two different communities, a separate analysis should be done for each commu-
nity.
To develop these worst-case release scenarios, one can refer to EPA documents such as “Risk
Management Program Guidance for Offsite Consequence Analysis,” which presents different
calculation tables and other recognized analysis methods. This document and these tables are
available on the EPA website at the following address: http://www.epa.gov/ceppo. Annex 6 con-
tains extracts from this document, as well as different EPA calculation tables. EPA has also devel-
oped the RMP*CompTM software, which can be used to perform the same calculations. A copy
of this software may be downloaded from the following Internet address:
http://www.epa.gov/swercepp/acc-pre.html. It is important to mention that the results obtained
with the aid of the EPA tables or software are on the conservative side; that is to say, the impact
distances are exaggerated. This precaution is necessary to account for the high level of uncer-
tainty. Other software programs are also on the market: ALOHA, PHAST, etc.
Although a spill meeting all the analysis conditions at the same time is unlikely to occur, this
analysis will serve as a starting point to identify the establishments for which a more in-depth
evaluation is necessary. The results of this first analysis will be used as a consultation tool for
developing emergency measure plans.
It is important to emphasize that if the establishment has a process that involves several inter-
connected vessels, or are situated inside the impact zone of other vessels, it is possible that an
accident may occur that is more serious than that of the worst-case scenario of the EPA. If cred-
ible scenarios exist that can be more serious (in terms of quantities spilled or consequences) than
the EPA worst-case scenario, the establishment should be prepared to inform the JCC of the sit-
uation. [See annex 5 ]

Chapter 3
Figure 2
Diagram – Process According to the RMP of the EPA
Hazardous materials
(Substance on the JCC list, No
classes A, B, C and D) End
Yes
No
Threshold End
quantity?
Yes
Worst-case No Five-year No
scenario accident history End
Yes
Five-year
accident history
Yes
Alternative Process safety Communications

accident scenarios management program
Harmonized emergency
response plans

Chapter 3
TABLE 2
Specific Conditions Related to the Development of
Worst-case Scenarios Required by the RMP1
TOXIC GASES AND LIQUIDS
Toxic gases
Toxic substances from the list appearing in gaseous form at 25°C.

1. Total quantity of the vessel or from a pipe failure of the most important process emitted in
10 minutes;
2. Take into account the passive mitigation measures.
Modelling of the emission consequences to determine the impact radii, according to the emission rate and
toxicity threshold, using the EPA tables or the appropriate software for this activity.
Toxic gases liquefied by refrigeration
Instantaneous emission of a gas liquefied by refrigeration.

Take into account the passive mitigation measures:
• If the pool thickness is greater than 1 cm:
1. Emission of gas from the pool at the boiling temperature of the toxic liquid
at atmospheric pressure.
2. Use of EPA tables or specific protocols to calculate the evaporation of gas
from a liquid pool.
3. Calculation of quantity emitted in 10 minutes.
• If the pool thickness is less than 1 cm:
Evaporation of all liquid spilled over a 10-minute period.
Modelling of the emission consequences to determine the impact radii, according to the emission
rate and toxicity threshold, using the EPA tables or the appropriate software for this activity.
Toxic liquids
Instantaneous emission of a toxic liquid.

For toxic liquids transported by pipeline, the greatest quantity that can be transported and spilled
in a pool should be taken into consideration.
• If there is no diked area, assume that the thickness is 1 cm and determine its surface:
1. Emission of gas from the pool, according to the vapour pressure of the toxic
liquid at 25°C.
2. Use of the EPA tables or the specific calculation protocols to calculate the
evaporation of the gas from a liquid pool.
Modelling of the release consequences to determine the levels of danger (toxicity) specific to the sub-
stance with the help of the EPA tables or the appropriate software for this activity.
1 Includes changes made January 6, 1999, by the United States Senate (U.S. Senate, S. 880, Clean Air Act Amendment
to remove flammable fuels from the list of substances with respect to which reporting and other activities are required
under the Risk Management Plan Program, and for other purposes, Washington, D.C., July 1999).

Chapter 3
TABLE 2 (CONT.)
Specific Conditions Related to the Development of Worst-case Scenarios
Required by the RMP
FLAMMABLE AND EXPLOSIVE GASES AND LIQUIDS2

Flammable substances from the list including flammable gases and volatile liquids
Substances stored in gaseous or liquid state under pressure
Total quantity of the vessel or from a pipe failure of the most important process emitted in 10 minutes.
1. Total mass of the substance for calculating the explosion consequences.
2. Efficiency factor of the explosion is 10%.
3. Distance calculated for a superpressure of 1 psi.
4. Use of EPA tables or protocols and appropriate equations for the calculation.
Modelling of the emission consequences to determine the impact radii, according to the emission rate
and the overpressures caused by the explosion, using the EPA tables or the appropriate software for this activity.
Flammable gases liquefied by refrigeration (cryogenics) at atmospheric pressure
Instantaneous emission of the total mass of liquefied gas.

If the liquid does not cover the entire surface of the dike or if there is no dike
(pool thickness less than 1 cm):
- The hypothesis is: the total mass of liquid evaporates in 10 minutes.
If the liquid covers the entire surface of the dike and forms a pool greater than 1 cm:
1. Calculate the evaporated quantity according to the EPA tables or the appropriate calculation protocols.
2. Calculate the quantity emitted in 10 minutes.
3. Total mass of the evaporated substance in 10 minutes to calculate the explosion consequences.
Flammable liquids
Instantaneous emission of the total mass of flammable liquid.

If the liquid does not cover the entire surface of the dike or if there is no dike
(pool thickness less than 1 cm):
- Evaporation in 10 minutes of the total liquid mass.
If the liquid covers the entire surface of the dike and forms a pool greater than 1 cm:
1. Calculate the evaporated quantity according to the EPA tables or the appropriate calculation protocols.
2. Calculate the quantity emitted in 10 minutes.
3. Total mass of the evaporated substance in 10 minutes to calculate the explosion consequences.
Note: This rule applies to volatile substances from the EPA list. For all other substances listed by CRAIM, the
vapour pressure must be taken into account and the quantity that will be evaporated must be deter-
mined.
Explosives
Total mass of the substance used to calculate the explosion consequences with the efficiency
characteristic of the particular explosive substance.
2 The section dealing with flammable substances was modified by law 880 of the United States Senate.

Chapter 3
Step 4 – Review of Accidents over a Five-year Period

Depending on the results of the analysis of the consequences of the worst-case release scenar-
ios, if it is determined that an accident has consequences outside the boundaries of the estab-
lishment (off-site), it is necessary to proceed with the analysis of the alternative accident scenar-
ios. It is also necessary to conduct a review of accidents covering the last five years for each of
the processes of the establishment targeted by the procedure.
After the analysis of the consequences of the worst-case release scenarios, if the results do not
demonstrate any consequences outside the boundaries of the establishment (off-site), it is still
necessary to conduct a review of accidents for a period covering the last five years.
This review of accidents covers only the following types of emissions:
• the emission must be for a substance on the list and for which the held quantity is greater
than the threshold quantity;
• the emission must have caused, on the site, death, injury or significant damage to property or,
outside the boundaries of the establishment, death, injury, damage to properties, environmen-
tal damage, evacuation or on-site containment.
For the establishments for which the results of the analysis of the consequences of worst-case
release scenarios do not pose any off-site impact, and for which the background review did not
lead to the identification of emissions, such as defined above, it is not necessary to continue with
the procedure.
Step 5 – Analysis of Consequences

Alternative Accident Scenarios
All the establishments that present off-site consequences, following the analysis of the worst-
case release scenario, or which have reported an accident in the five-year background review,
proceed next to an analysis of the alternative accident scenarios. This analysis will be used to
prepare the emergency response plans.
The analysis is conducted according to the parameters defined by the EPA for “alternative acci-
dent scenarios.”
The alternative accident scenario represents the most severe accident that can occur for a listed
hazardous material, held in a quantity exceeding the threshold quantity. This scenario takes into
account the proximity or interconnection of the vessels containing the substance involved.
However, it also takes into account passive and active mitigation measures.
The Number of Scenarios to Present
An alternative accident scenario must be presented for each of the toxic substances contained
on the list and held by the establishment in quantities exceeding the threshold quantity. Only
one alternative scenario must be presented for all the flammable substances held.
The choice of alternative scenarios to present will be made after analyzing the possible acci-
dents, based not only on experience and judgment, but also on certain methods that take into
account probability. To do this, the background review of company accidents and research on
accidents occurring in a similar domain elsewhere are good indicators. It is understood that the
choices made must be justified by serious analysis.
Once the scenarios are chosen, the impact of a hazardous material released in the atmosphere
on the area surrounding the establishment will be evaluated. The calculation is made by taking
into account the harshest meteorological conditions for the region. The impact zones are rep-
resented by circles centred on the source of the accident.

Chapter 3
This evaluation will provide information on the approximate number of people affected inside
the circle and will also identify the public buildings affected, such as schools, seniors’ residences,
hospitals, etc. As well, environmental impacts will be considered, depending on the site affect-
ed.
For flammable products, it should be pointed out that the hazardous substance used to estab-
lish an alternative accident scenario may differ from the substance used to analyze the conse-
quences of a worst-case release scenario. In fact, it may arise that the alternative accident sce-
nario for the substance considered the most hazardous at the time of choosing a worst-case
release scenario has a lower impact zone, after risk mitigation, than one of the other hazardous
substances reported by the establishment.
The schematic representation (Figure 3) on the next page outlines the five-step approach for the
analysis of the risk of major industrial accidents.
The analysis of accident consequences must also be used for preparing emergency response
plans, which are intended to limit damage to individuals, to the environment and to property,
in case of an emergency situation. It then becomes possible to harmonize the response plan of
the establishments with that of the municipality/municipalities concerned and with the plan of
other responders. This harmonization will allow a quick and efficient response. [See annex 5]
As well, the analysis of the accident consequences allows the public to be informed about the
risks contained in their environment. This awareness, by informing the citizens of the prevention
measures taken by the establishments to reduce the risk and consequences of accidents, also
allows the citizens to be informed about the measures taken by the municipality to respond in
case of an emergency situation, as well as the measures that the citizens must take to prepare
and protect themselves. [See annex 5]

Chapter 3
Figure 3
Schematic Representation of the CRAIM Process
Hazardous No
Step 1 material from
the list
Yes
Greater
or equal to the No
Step 2 threshold WARNING
quantity
Yes
Class of the
Step 3 E or F ? hazardous
material
Yes
A, B, C, or D ?
WORST-CASE
SCENARIO
Five-year
Consequences No accident No
off-site? background? END
Yes Yes
Five-year
Step 4 accident
background?
Step 5 Alternative Process safety Communications/

scenarios management program/ Chapter 7
Chapter 4
Harmonized
emergency response
plan / Chapter 6

Control of Risks
and Actions/Monitoring
4
Chapter
35
Chapter 4
Industrial Safety
T he analysis approach previously described has three objectives: preventing major industri-
al accidents by establishing process safety measures, establishing and harmonizing emergency
plans, and communicating information to citizens on the safety measures taken by the munic-
ipalities and companies and on how to protect themselves in case of accident.
Accordingly, it is recommended that establishments implement a process safety management
program. The enforcement of these management principles is intended to prevent accidents in
facilities that manufacture, store, handle or use these hazardous substances.
In this program, the objectives can be achieved by developing a management plan that corre-
sponds to the risks and consequences following from the worst-case release scenarios. To this
end, the information provided by the EPA is invaluable. [See annex 5]
In Quebec, the Law on Workplace Health and Safety covers the safety of facilities and workers
in their general work context. These standards may form the basis of a process safety approach.
Other models are also available and can be of invaluable assistance in this approach. MIACC
(Major Industrial Accidents Council of Canada) has produced a document describing the main
elements that constitute a process safety management program. In the United States, OSHA’s
“Process Safety Management” (Occupational Safety and Health Administration) and API 750
(American Petroleum Institute) are helpful guides.
The risk management measures listed in this step not only are, as indicated, dealt with in the
EPA approach, but also are the subject of particular publications. (Example: specialized manuals
from CCPS—Center for Chemical Process Safety of the American Institute of Chemical
Engineers.)
Table 3 briefly presents the elements that make up process safety according to MIACC.

Chapter 4
Emergency Preparedness Program

at the Municipal Level
The emergency preparedness model of Quebec is based on a six-step approach. Although appli-
cable to municipalities, establishments and ministries, this approach tends to be used mainly by
municipalities.
According to the ministère de la Sécurité publique du Québec (MSPQ, 1994), emer-

gency preparedness is defined as being the set of measures that:
• aims to prevent a disaster from occurring or strives to reduce the effects;
• protects people and safeguards goods in case of a disaster; and
• fosters the return of life to normal after a disaster.
It is important to know that municipalities are responsible for planning emergency preparedness
on their territory. The planning rests on a certain number of guiding principles. As well, this
approach requires careful consideration of the current and potential status of the situation.
A focus on the following points is strongly recommended:
• Are the realities known?
• What risks are incurred?
• What types of disasters could occur? What consequences are foreseeable?
• How can responses to counter the effects of a given disaster and restore things to normal
be planned?
• Are the human resources ready to respond? Are the material resources adequate? Are the
financial resources sufficient? (MSPQ, 1994)
The emergency preparedness planning approach includes these six steps:

• a knowledge of the milieu;
• a vulnerability study;
• implementation of prevention and mitigation measures;
• response planning in case of disaster;
• implementation of measures aimed at making the agency capable of responding; and
• update and review.
For more complete details, the direction de la sécurité civile du ministère de la Sécurité publique
has provided, in a basic manual on emergency preparedness in Quebec, a reference context so
as to properly define emergency preparedness, foster the coordination of responses during a
disaster and clarify the role of responders in emergency preparedness. This manual was com-
pleted by using tools (such as Principes de Planification d’Urgence Conjointe Municipalité Milieu
de l’Enseignement) adapted to different clienteles and tools provided in emergency prepared-
ness training programs at the college level.

Chapter 4
TABLE 3
Elements of Process Safety*
*Source: Process Safety, first edition, Major Industrial Accidents Council of Canada, 1994.
1. Responsibility: Objectives and aims
- Operations continuity - Communications

- Alternative methods - Quality process
- Systems continuity - Company expectations
- Accessibility of decision-makers - Control of exceptional cases
- Organizational continuity
2. Process knowledge and documentation
- Dangers linked to work safety and - Risk management decisions

chemical products - Process and equipment design
- Operating procedures for normal operating - Company archives (information management)
conditions and disturbances - Protection systems
- Process definition / design criteria
3. Review of investment projects and design procedures
- Procedures for approval requests - Procedures for control and project management
- Procedures for design and review - Choice of location
- Review of hazards - Implementation outline
4. Process risk management
- Identification of hazards - Choice of business sectors with acceptable risks

- Incentives for clients and suppliers to adopt - Reduction of risks
similar risk management practices - Management of residual risks
- Analysis of operating risks - Process management during emergencies
5. Management of change
- Changes in the process technology - Organizational changes that can have an

- Dispensation procedures impact on process safety
- Changes to facilities - Permanent changes
- Temporary changes
6. Integrity of equipment and processes
- Reliability - Installation procedures

- Test and inspection of processes, equipment - Management of alarms and instruments
and systems (pre-startup safety review) - Preventive maintenance
- Construction material - Permanent stop and demolition procedures
- Manufacturing and inspection procedures

Chapter 4
TABLE 3
Elements of Process Safety*
*Source: Process Safety, first edition, Major Industrial Accidents Council of Canada, 1994.
1. Responsibility: Objectives and aims
- Operations continuity - Communications

- Alternative methods - Quality process
- Systems continuity - Company expectations
- Accessibility of decision-makers - Control of exceptional cases
- Organizational continuity
- Dangers linked to work safety and - Risk management decisions

chemical products - Process and equipment design
- Operating procedures for normal operating - Company archives (information management)
conditions and disturbances - Protection systems
- Process definition / design criteria
3. Review of investment projects and design procedures
- Procedures for approval requests - Procedures for control and project management
- Procedures for design and review - Choice of location
- Review of hazards - Implementation outline
- Identification of hazards - Choice of business sectors with acceptable risks

- Incentives for clients and suppliers to adopt - Reduction of risks
similar risk management practices - Management of residual risks
- Analysis of operating risks - Process management during emergencies
- Changes in the process technology - Organizational changes that can have an

- Dispensation procedures impact on process safety
- Changes to facilities - Permanent changes
- Temporary changes
6. Integrity of equipment and processes
- Reliability - Installation procedures

- Test and inspection of processes, equipment - Management of alarms and instruments
and systems (pre-startup safety review) - Preventive maintenance
- Construction material - Permanent stop and demolition procedures
- Manufacturing and inspection procedures

Residual Risk/
Vulnerability Study
Chapter
5 41
Chapter 5
F ollowing the implementation of prevention and mitigation measures in case of

an incident, companies must prepare themselves for emergencies that could still occur
(i.e., residual risks) due to unforeseen circumstances or failure of the prevention, mit-
igation or management systems. The first step of this preparation phase is to identify these
situations. This step must answer the question “What are the potential incidents that may result
in an emergency for which companies must prepare themselves?” The identification of these
situations is an integral part of the hazard study, one of the elements of the process safety pro-
gram (Chapter 4). Facilities that carry out a proper hazard study identify a large number of
potential accident scenarios as a result.
A vulnerability study entails a two-pronged approach:
• risk analysis; and
• analysis of the capacity to respond according to the consequences of the risk analysis.
Following the risk analysis, the responsible municipal and industrial authorities must consider
their capability to respond to the identified risks. To do this, the authorities must evaluate if the
resources in place are adequate. It is important to remember that the vulnerability study is first
and foremost a comparative tool that will allow—once the results are known—undertaking the:
• development of an emergency plan (Chapter 6); and
• evaluation of the goal of the objectives (Chapter 8).
Analysis of the Response Capability of

the Industrial Sector
Emergencies involving hazardous materials rarely entail a single event. Most of the time, there
are several contributing causes and intermediary events, including the triggering of automatic
safety devices and human intervention. It is generally recognized that it is impossible to identify
all possible causes, intermediary events and final consequences of potential accident scenarios.
If all these factors were considered for a complex facility, the number of accident scenarios
resulting in toxic or flammable emanations, fire or explosion would be too large to be useful in
prevention and planning. The typical approach for the hazard analyses consists of identifying the
accident scenarios that are the most plausible.
For example, in the event of a leak in a mechanical gasket, one of the following situations may
occur: A very small leak that will vaporize right away or a leak of several gallons of liquid a
minute that will accumulate in the dike. The analyst’s work will be to cover the entire gamut of
consequences for a single potential accident scenario that will identify the most serious conse-
quences (and probably the low-priority ones as well). This directs the analysis toward the most
serious potential incidents.
The establishment must evaluate and declare a worst-case release scenario for all the toxic sub-
stances and another scenario for all the listed flammable substances held in excess of the thresh-
old quantity.
The establishment may submit an additional worst-case release scenario, if another sensitive
area is potentially affected.

Chapter 5
After identifying the flammable and toxic substances and developing the worst-case release sce-
narios, the alternative accident scenarios must be developed. To do this, it is necessary to iden-
tify the plausible accidents that carry an impact outside the establishment in sensitive areas. The
methods for identifying these accidents range from informal techniques to a detailed hazard
study. The informal techniques can be used effectively if the planners have vast experience of
the processes studied. The formal techniques also require pertinent hazard study experience for
the facilities studied but are usually more rigorous and lead to rational choices for developing
plausible scenarios.
Whatever the approach, it is necessary to clearly define the accidents that may occur in order to
be in a position to plan the response measures. The establishment must present information on
an alternative accident scenario for the flammable substances and an alternative accident sce-
nario for each listed toxic substance held in excess of the threshold quantity, including the sub-
stance used to conduct the worst-case scenario.
Once the list of potential accidents is compiled, it must be analyzed to choose a certain number
of scenarios for modelling and the detailed consequences study.
The consequences of potential accidents generally include a toxic or flammable gas or liquid
emission, a fire or an explosion.
An emission of toxic or flammable liquids or gases will generally have one of the fol-
lowing consequences:
• release, evaporation and/or formation of aerosol;
• dispersion of a toxic or flammable cloud;
• fire; or
• explosion.
Several models exist for evaluating these consequences:
• RMP*CompTM of EPA; and
• ALOHA.
The development of alternative accident scenarios will help identify response strate-
gies in emergency situations. The accident scenarios will allow planners to:
• identify the types of equipment required;
• determine the human resources required and their expertise; and
• develop appropriate response strategies.
First, the planners must receive the plausible scenarios and identify the consequences of the acci-
dents with which the establishment may be faced. Next, they must define the best way to use
the resources at their disposal internally and externally, including governmental agencies and
industrial mutual aid groups alike.
After identifying the available resources, the planners must develop a strategic response for the
credible accidents. This is important, as the establishment may not have adequate capabilities
and response resources to respond safely during certain credible accidents. It thus follows that
planners must identify the alternative response strategies. The alternatives may include increas-
ing personnel, adding equipment, using contractors, using governmental agencies or establish-
ing municipal/industrial mutual aid plans.
The objective of this activity is to establish a balance between the consequences of credible acci-
dent scenarios and the resources required to respond effectively to ensure that the situation
remains safe for all.

Chapter 5
Analysis of the Response Capability of

the Municipal Sector
For the municipality, the vulnerability study is the examination of the results of the risk analysis
and the response capability of an agency that must respond during a disaster linked to detect-
ed risks. The vulnerability study allows the agency to plan prevention or mitigation measures, to
plan responses in case of disaster and to implement measures or activities intended to make it
capable of responding.1
The committee therefore analyzes the capability of the agency to respond for each of the pre-
viously held risks. To this end, the committee will take into consideration the resources of the
agency as well as the external resources on which it may call.
The analysis of the response capability is done by:
• Establishing, for each of the risks, the desired response capability to be effective, in terms of
the agency’s human, material and organizational resources (operating methods or proce-
dures). Also evaluated are the information capacity and the required mobilization of the
agency to obtain appropriate help from external resources (governmental, municipal or pri-
vate agencies) located on or outside its territory.
• Establishing, for each of the risks, the current response capability of the agency according to
the same method as before, but based on the existing resources.
• Establishing the discrepancy that exists between the current response capability and the
desired capability.
• Determining the risks that must be prioritized, following the identification of discrepancies in
the response capability. The activity consisting of analyzing the agency’s response capability
can also be carried out by a team working under the responsibility of a member of the emer-
gency preparedness committee.
The municipality does not have to carry out alternative scenarios and make an inventory of all
the potential incidents. However, it must analyze the scenarios proposed by the establishments
and evaluate its response capability regarding these scenarios or residual risks.
1
MSP, Emergency Preparedness in Quebec, basic manual, March 2, 1994, page 36.

Development of
an Emergency Plan
6
Chapter
47
Chapter 6
D espite proper risk management, a residual risk will always exist. An accidental event will
occur and create a situation requiring an immediate and appropriate response. The emergency
plan determines the responses of industries and/or municipalities during emergencies such as
spills, explosions, fires or natural disasters like ice storms, earthquakes, floods or other storms.
The CAN/CSA-Z731-95 standard has been published to help industries develop their emergency
plan and coordinate efforts with municipal responders. Along the same line of thought, the
Commission de la santé et de la sécurité du travail au Québec (CSST) has also published a guide
entitled “Planning Emergency Measures to Ensure Worker Safety.” Section 1 of this document
outlines the main elements of an emergency measures plan.
In each emergency situation, there is a period of confusion and disorder. Proper emergency plan-
ning and preparedness reduce these risks.
Communication between the different responders proves to be equally important; this is why it
must be integrated with the emergency plan. It appears that everyone can practise and com-
municate amongst themselves the different information required for the emergency planning
and the corresponding response.
The emergency plan must be concise but must also contain sufficient information to enable a
prompt response.
An effective emergency plan must strive to:
• ensure the protection of workers, responders and the public;
• reduce the potential risks;
• reduce the environmental impacts;
• determine the types of emergency possible with respect to the industry; and
• determine the response methods.
However, it is very rare that an event occurs as expected in the scenarios developed in the risk
analysis. As a result, the emergency plan must be flexible, be constantly updated and leave room
for the initiative of managers.
To develop an emergency plan, please refer to the CAN/CSA-Z731-95 standard and to section
1 of the CSST document.
In the context of testing the emergency measures plan, the chronological response scenario is
a very useful tool for evaluating the reliability and work quality of the emergency measures plan-
ning.

Risk Communication and
Emergency Situation
Communication
7
Chapter
51
Chapter 7
T his chapter is intended for decision-makers and other responders working in the
area of prevention and management of major industrial accidents and coming from
municipalities, companies and government institutions. It will be of particular interest
to communication personnel as well as managers and personnel called on to disclose
the risks of major industrial accidents to the public, manage a command post in emer-
gency situations or act as spokespersons.

Chapter 7
Introduction
Since the 1970s, when the public increasingly demonstrated its concern about nuclear power
plants, risk communication has been the subject of numerous studies and publications. It is now
an integral part of all risk management processes.
According to a U.S. National Research Council committee in charge of studying risk perception
and communication:
“Risk communication is an interactive process of exchange of information and opinions among
individuals, groups and institutions. It involves multiple messages about the nature of risk and
other messages, not strictly about risk, that express concerns, opinions, or reactions to risk mes-
sages or to legal and institutional arrangements for risk management.”1
As for the Privy Council Office of the Government of Canada, it defines risk communication as:
“The interactive (two way) exchange of information and opinions on risk and risk-related fac-
tors (including the existence, nature, form, severity, or acceptability of risk and how they should
be managed) among risk assessors, risk managers, consumers and other interested parties
(stakeholders) in order to achieve a better understanding of risk, risk management, risk-related
issues and decisions.”2
What one must remember about these definitions is that risk management is truly an interac-
tive and multilateral process that involves everyone (including both citizens and other respon-
ders) facing the risk of a major industrial accident. The decision-makers must take into account
the public’s level of understanding, their concerns (well founded or not) and their perceptions
in a given situation. This also necessitates that this process is continuous and that it applies
throughout four critical moments, namely:
• in normal time (before an emergency);
• in a preventive alert situation (or exercise or simulation);
• in an emergency situation (e.g., major industrial accident); and
• after an emergency (evaluation period and restoring the situation to normal period).
Risk communication experts have widely shown that poor risk communication can have very
serious consequences: loss of confidence and mistrust of the public and the media (toward the
company involved and municipal decision-makers or other levels of government), loss of credi-
bility of managers and responders in emergency situations, confusion in the response, possible
attack on the safety of the response team and the public, etc.
On the other hand, a good risk communication plan will help in assuring the safety and well-
being of personnel, the public and the environment, preserving the economic health of the
company and facilitating operations in emergency situations.
This chapter serves as a practical guide for planning and implementing a good risk communica-
tion plan and an effective communication strategy in emergency situations. It is made up of a
synthesis of several studies and tests on risk communication and was the subject of a consulta-
tion by communication experts. Rounding out the chapter are some practical tools that will be
useful for planning and organizing communications in emergency situations.3
1
U.S. National Research Council. 1989. Improving Risk Communication. Committee on Risk Perception and Communication.
National Academy Press, Washington, D.C. 332 pp.
2
Canada. Privy Council Office. Risk Management for Canada and Canadians: Report of the ADM Working Group on Risk
Management. [Ottawa]: Privy Council Office, 2000. 31 pp. URL: http://www.pco-bcp.gc.ca/
3
The annexes found in this chapter contain different documents dealing with the media in emergency situations, the role
and responsibilities of spokespersons, communication tools (types and uses, relative effectiveness according to the situa-
tion, advantages and drawbacks), and a tip sheet for media relations in emergency situations.

Chapter 7
Context
As mentioned several times in this guide, risk communication is a vital part of the process of pre-
venting and managing major industrial accidents. [See Chapters 3 and 8, Annexes 4 and 5]
In an emergency situation setting, the communications responsibility must be assumed and facil-
itated by the coordinator and the entire team involved in the management of the crisis or emer-
gency situation. The municipal authorities are in charge of communications with their citizens
when a major industrial accident occurs on their territory and must rely on the cooperation of
the company concerned and that of the different government responders that respond in sup-
port.
Risk Communication
In normal time • Know the risks

(before an emergency) • Know the prevention systems
• Gather the concerns of the surrounding
population
• Establish a dialogue with the municipality,
the population and the government respon-
ders
• Inform the internal personnel, the municipali-
ty, the surrounding population and the other
concerned responders of measures that will
be implemented during an emergency
• Prepare the tools in case of emergency
In a preventive alert situation

• Find out about the situation
(or exercise or simulation) • Set up a communication centre, if needed
• Establish links with the responders concerned
In an emergency situation
• Establish direct links with the on-site
(e.g., major industrial accident) responders
• Inform the personnel, the municipality, the
population, etc.
• Communicate the information to the media
and answer their questions
• Establish privileged links with the municipality
and the government agencies concerned
After an emergency
• Establish an event and response assessment
• Communicate the assessment to the con-
cerned parties

Chapter 7
Risk Perception and Basic Principles

Although the risk of a major industrial accident or an emergency situation may appear—to the
eyes of the decision-makers—to be under control and pose no danger for the population, the
perception may well be otherwise for communities susceptible to being affected by, or victims
of, a disaster. Several factors influence risk perception. American author Vincent Covello4 has
studied this question at length and has identified no fewer than 47 factors that influence risk
perception. Among the most important are:
• Voluntary or involuntary risk (a smoker takes a voluntary risk, but he or she less readily
accepts an imposed risk, such as the emissions coming from a nearby factory—even though
these very emissions sometimes cause less pollution than the smoke from his/her two packs
of cigarettes a day)
• Natural or technological risk (people have a tendency to accept with a certain fatalism
natural catastrophes such as storms and floods, but react strongly to technological accidents
that could have been prevented)
• Credibility of organizations (an accident will be better accepted if the company at fault
has good credibility, whereas a minor accident can generate a lot of concern by the public if
the company in the wrong lacks credibility)
• Understanding of risks (the public will not accept taking a risk that it does not under-
stand; this is precisely what happened—among other things—during the environmental
assessments for the raising of the Irving Whale in 1996, when the public doubted the effec-
tiveness of the method used)
• Association phenomena (since the fire of a PCB warehouse at Saint-Basile-le-Grand in
1988, all PCB-related incidents, or even the storage of PCBs in a safe area, are perceived as
a catastrophe)
• Equity and ethic (people will react negatively if their situation appears unjust, like the
repeated evacuations at Fleurimont, near Sherbrooke, or if it could have been prevented:
“We knew it!”)
• Control of the situation (public concern is influenced by the capacity to control the situa-
tion or the appearance of controlling it; the ice storm in 1999 was relatively well accepted
by the affected population, as there was the appearance of controlling the situation at the
highest management level of business and government)
In all risk communication, certain basic principles must be respected that will support all the atti-
tudes and actions of all responders from the private, municipal and governmental sectors.
Covello and Allen have proposed seven basic rules that are used today by several specialists, at
all steps of the process:5
• Accept and involve the public as a legitimate partner.
• Plan carefully and evaluate your performance.
• Listen to the public’s feelings.
• Be honest, open and frank.
• Coordinate and collaborate with other credible sources.
• Meet the needs of the media.
• Speak clearly and with compassion.
4
See the bibliographical references of this author in the bibliographical Annex.
5
V.T. Covello and F. Allen. Seven Cardinal Rules of Risk Communication. U.S. Environmental Protection Agency, Office of
Policy Analysis, Washington, D.C. 1988.

Chapter 7
Steps and Detailed Plan of Action
Identification of the Issues

or Evaluation of the Emergency Situation
As the risk communication process is a continuous process, the issues or that which is perceived
as a risk by the public must first be identified. This step must be done in normal time, or after
an emergency response, to portray the situation realistically. This can be done together with cit-
izens, for example, through meetings with representative groups, public information gatherings
where citizens will be allowed to express their concerns, opinion surveys, etc. It is also important
to involve the personnel of the municipality and the company in the entire communication
process.
The scope of a Joint Coordinating Committee (JCC), as described in this document, allows ini-
tiating this dialogue between the municipalities, the companies and the population. By work-
ing together on the risk analysis, prevention, response planning and public information on the
risks and the safety measures to take, the responders and citizens will also work to identify the
different issues and modify their perceptions.
Whatever the form of this communication between the public, the municipality and the com-
pany, it must be set up to respect the interests of each party and according to the natural pro-
gression of the perceptions.
The simulation exercises or training activities of those called to respond to an emergency situa-
tion will also provide opportunities to involve the public and put the risk communication plan to
the test.
In an emergency situation, as stated in the previous chapters, the seriousness of the situation
must of course be assessed from the viewpoint of the company and the decision-makers. Above
all, the short- and long-term concerns and perception of the public must be kept in mind. In an
emergency situation, the public is first concerned for its health and safety; other questions arise
afterwards: shelter, reimbursement of incurred expenses, insurance, psychological impacts,
effects on the environment, devaluation of their property, etc.
Finally, at each step of the risk communication process, assessments will allow the person
responsible for communication to estimate the gap to fill between the objective understanding
of the issue or the emergency situation, the understanding of the citizens and the internal
responders, the willingness and the ability to adopt safety behaviour, etc.
Target Public
For a risk communication process to be effective, it is important to properly understand the tar-
get public beforehand. In the scope of risk analysis, the company will determine with the munic-
ipality’s help the residential sectors susceptible to being affected by a major industrial accident,
as well as the public, health and shelter buildings located in this area.
The interested groups and parties will also be identified, even if they are not inside the target
area. These include environmental groups, departments that will be concerned eventually,
health services and service suppliers (gas, electricity, insurance, etc.).
The employees of the company and the municipality must not be forgotten, as they will be (in
emergency situations) the informal spokespersons to the public, and even to the media—who
do not always turn to official spokespersons.

Chapter 7
A media list by chronological order of deadlines (local electronic media, regional media, daily
print media, and then periodicals) will also be established and updated regularly, without for-
getting the Web sites of the company and the municipality with possible hyperlinks to other
sites.
Finally, in an emergency situation, according to the responsibilities granted to the person respon-
sible for communications in the emergency measures plan, the following parties must be
informed: the persons present in the affected area, the company head office or administrators
of the municipality, the family of a person injured or killed during the accident, the main recep-
tionist, the other employees that are part of the emergency team, the concerned agencies from
the three levels of government and the immediate vicinity, the general public via the media, the
insurance companies and other concerned public or private agencies. The order of priority in
which these parties are informed will depend on the nature of the accident.
Communication Goals
The main goal of risk communication is to inform citizens and personnel about the potential
risks that can occur in an industrial facility, the prevention measures put in place or anticipated
by the companies, the municipalities and the citizens themselves should an accident occur, as
well as the measures to take to facilitate restoring the situation to normal after a disaster.
However, according to Dr. Douglas Powell of the University of Guelph:
“Problems in communicating about risks originate primarily in the marked differences that exist
between the two languages used to describe risk: the scientific and statistical language of
experts, and the intuitively-grounded language of the public. (...) Good risk communication
practice seeks to break down those barriers and facilitate the productive exchanges between
the two spheres in terms of information, skills and participatory opportunities.”6
An appropriate level of language and putting the complex information into layman’s terms are
therefore essential.
The development of communication goals should take into account the estimated gap between
the knowledge, understanding and perceptions of the different target publics. As well, it should
attempt to reduce this gap in order to maintain good communication with the target publics in
normal situations and assure the smooth running of operations in emergency situations.
For example, the goal could be to:
• ease the concern of citizens regarding industrial activities perceived as dangerous for their
safety;
• make the employees of a company or a municipality aware of the importance of their role
in broadcasting alarmist rumours in emergency situations;
• establish a climate of trust between the potential responders of various sectors in case of a
future emergency situation;
• optimize the coordination between the members of a team in case of a major industrial
accident; or
• foster the adoption of safety behaviour during preventive alert or emergency situations.
6
Douglas Powell. “Risk Communication—Hog Environmental Management Strategy.” In: Proceedings for the Joint
Canadian Pork Council and Agriculture and Agri-Food Canada Workshop on Hogs and the Environment. [Ottawa]:
Agriculture and Agri-Food Canada, 2001. 21 pp. http://res2.agr.ca/initiatives/manurenet/en/hems/powell.html

Chapter 7
Communication Approach
Generally, the communication approach should always be proactive—namely, it should be done
at all times of risk communication (before, in preventive alert, during and after). The approach
must anticipate the information needs of the different target publics and not wait passively for
the requests of the public, colleagues and the media. It will be to the advantage of organiza-
tions involved in risk communication and emergency situation communication to put the mes-
sages to the test during training sessions of personnel called on to respond in emergency situ-
ations or during simulation exercises.
The approach that is appropriate to the situation and to the needs of those on the receiving end
must be identified in concrete terms. The choice of the communication tools and spokesperson
will depend on this approach.
For example, the approach used could be to:
• widely publicize a consultation process in the scope of the development of an emergency
plan or, conversely, specifically target a small number of responders concerned by a
particular aspect;
• communicate simultaneously with a collection of groups and agencies by e-mail, or commu-
nicate in order of priority with pre-selected groups and agencies; or
• demonstrate the corporate involvement of the company by choosing a high-level spokesper-
son, or promoting the broadcast of factual and technical information by a scientific
spokesperson or an operations specialist.
Content of the Communications and Messages

It is essential to prepare answers to questions that are likely to be asked by citizens, the media,
personnel and other responders. The EPA document entitled “General Guidance for Risk
Management Programs,” from which extracts are included in Annex 5 of this guide, contains
several examples of questions and answers that could be prepared in advance.
These questions, known as the 5 Ws of journalism, are taken from the following:
• Where? (is the risk, did the accident occur, are the impacts, etc.)
• When? (will the preventive alert sound, did the accident occur, can we go back to our
homes, etc.)
• How? (did it happen, can we protect ourselves against toxic emissions, etc.)
• Why? (did it happen, evacuate or not evacuate, use such a toxic product, etc.)
• Who? (is responsible, is the spokesperson, is taking care of insurance claims, etc.)
• How much? (time, money, people evacuated, product, etc.)
With the knowledge that risk communication is a multilateral and not a one-way process, it is
important to be able to produce messages that take into account differences in the target publics’
knowledge, interests and perceptions. It might be worthwhile to test the effectiveness of mes-
sages on some people who are representative of the target publics.
It is very difficult to produce and distribute clear and effective messages, particularly in emergency
situations. This is especially true for dealing with the media, who have requirements and con-
straints—particularly the electronic media—to which the spokespersons must adapt. One must
remember that the media have to abide by very strict deadlines and that the length of the
responses do not exceed one or two minutes in the electronic media. Annex 1 entitled “The
Media in Emergency Situations” at the end of this chapter provides more details on this.

Chapter 7
Covello et al. (1993) have offered the following guidelines for communicating infor-
mation on risks:7
• Be balanced and honest.
• Focus on a specific issue.
• Pay attention to what the audience already knows.
• Be tailored to the specific needs of the audience.
• Place the risk in an appropriate context.
• Present (at least) the specific information needed to resolve the decisions that members of
the audience face.
• Be hierarchically organized so that people who only want answers can find them quickly,
and people who want details can also find them.
• Be respectful in tone and recognize that people have legitimate feelings and ideas
• Be honest about the limits to scientific knowledge.
• Consider and address the broader social dynamics in which risks are embedded.
Lastly, the use of metaphors, analogies and examples is often very useful to explain technical
and scientific phenomena. Simplicity, clarity as well as empathy must be fostered during the
development and broadcast of messages; all uncertainty or missing information to come must
be clearly indicated.
Organization and Communications Logistics

Several organizations have communication specialists. Some delegate the responsibility of risk
communication, particularly in emergency situations, to external consultants. This decision can
sometimes be seen as a lack of involvement and can have drawbacks for the communication
plan, both internally and externally, if it is poorly planned. Among these drawbacks are the con-
sultant’s level of understanding or backing of the company culture, the level of understanding
of the principal players of the local community, the consultant’s being out of touch with the net-
work of regular responders, as well as the relative concern of the consultant for the communi-
ty’s short-term needs and for the more long-term brand image of the organization. This is why,
if the company chooses to call on an external consultant, it must integrate the consultant early
on with its risk management team and make sure of the consultant’s availability in emergency
situations. The communication consultant can also act as an advisor to the organization’s
spokesperson if the latter does not have all the necessary skills.
In all cases, the pre-designated individual in charge of communications must be involved at all
steps of the risk communication process. During a major industrial accident, this individual must
be notified immediately and the response authorities in charge must make available to him/her
all the necessary resources. Next, he/she must:
• together with the response coordinator, assess the extent of the situation and the
foreseeable impacts on the public;
• anticipate the information needs of the public and the media;
• plan a message for the press (factual account of the situation) and more specific messages
(measures to take, control of the situation);
• coordinate the logistic needs of the communications;
• choose the appropriate communication tools and methods and produce the required
information material;
• assure proper internal broadcast of the information (within the team and at the hierarchical
level);
• allow for community feedback and comments of on-site team members; adjust the com-
munications as needed and immediately correct all false rumours;
7
V.T. Covello, B. Fischhoff, R.E. Kasperson, and M.G. Morgan. 1993. Comments on “The Mental Model” meets “The
Planning Process.” Risk Analysis, 13, p. 493.

Chapter 7
• constantly evaluate media interest and the type of coverage, and adjust the strategy
accordingly.
• maintain contact with the persons responsible for communications of other concerned
organizations; and
• at the end of the response, review the communication actions during the debriefting done
by the team to improve future responses.
Logistics
The communication plan must also anticipate the communication logistics in emergency situa-
tions. All could be put in place quickly to allow the person responsible for communications to
operate in an optimal manner, in the same way as the command station.
The communication centre must be located close to the coordination centre. The entire struc-
ture can be set up or built with the equipment existing on-site, depending on the size of the
emergency. It may, among other things and as needed, contain the following equipment: work
desks, computers with Internet access, telephones, cellular phones and photocopiers, photo-
graph, radio and television devices, VCR and tape recorder (for press review), etc. The need for
graphic design and courier services, support personnel, as well as an operating budget should
also be anticipated.
The person responsible for communications must also keep a log book, which will register all
the actions taken. A log should be kept for the information requests and visits of citizens, part-
ners and the media, as well as for the follow-up that will have been done. Sheets will also be
completed that summarize the interviews granted to the media and, if necessary, the media cre-
dentials of the journalists, to allow them access to a site surrounded by a security perimeter. In
the event of public information sessions or press conferences, a register of the participants will
also be maintained.
Communication mechanisms must be established with the rest of the team (telephone and e-
mail lists, meetings, report transmissions, display of organizational chart and coordinates of part-
ners network, plans and geographic maps, etc.).
If needed, a call centre for the public or information posts at nerve centres (city hall, police sta-
tion, local health, education or leisure facilities) will be organized, with resource people to pro-
vide the information. It is imperative, at all times, that these people possess the best and the
most recent information available and that they all communicate the same messages, in the
same way.
In case of evacuation, a reference and information centre on the shelter sites will have to be
established along with specialized personnel there. The logistical needs (according to the emer-
gency plan) will have to be anticipated, the feedback of the coordinators will have to be
obtained and daily information sessions will have to be organized for the front-line personnel.

Chapter 7
Circulation of Information
As much as possible, the person responsible for communications and the spokesperson should
attend coordination meetings and maintain regular contact with the team. In certain cases, a
liaison agent can be appointed who will be responsible for gathering the necessary information
and transmitting it to the person responsible for communications and the spokesperson. This
agent could also transmit the information to the coordination centre (analysis of the media cov-
erage, community reactions and feedback, etc.). It should be pointed out, however, that all
intermediaries add a risk of distortion.
The person responsible for communications must also maintain constant contact with his/her
counterparts from the other agencies involved in the emergency situation. Adaptable informa-
tion transfer mechanisms must therefore be put in place (distribution lists by facsimile or e-mail,
controlled-access Internet site, etc.).
Communication Activities and Tools

Various communication tools and methods could be used, depending on the extent of the sit-
uation, the territory to cover, the length of the response, media interest, etc. In Annex 3 at the
end of this chapter, more details are provided on the types of tools, their uses, their relative effec-
tiveness depending on the situation, and their advantages and drawbacks. Among the available
tools are:
• Media relations (interviews, information sessions or press conferences, news releases);
• Direct contacts (public assemblies, participation in JCCs, information sessions, information
tours or stands in public places, telephone contacts); and
• Information tools (information leaflets; posters or stickers; Web sites and e-mail;
PowerPoint presentations; tables, maps and diagrams).
Debriefing of Communication Plan

and Continuous Update
After an emergency response, the person responsible for communications must evaluate the
communication plan together with the team and the community representatives. The opera-
tions journal, the different request-for-information sheets from the public and the media, as well
as the press coverage will all be analyzed.
The strong and weak points will be identified, as well as the shortcomings to correct from a con-
tent and communication logistics perspective. This exercise will allow the team involved in risk
management and emergency situations to correct the errors and improve different aspects of
the communication plan.

Chapter 7
ANNEX 1:
The Media in Emergency Situations
T he media are the most important information source for the public. It is estimated that
television is the principal source of general information for 70% of the population. Moreover,
80% of people listen daily to the radio, which is the main information source for local news for
20% of the citizens. In Quebec, there are 12 daily newspapers, more than 200 weekly papers
and over 300 periodicals. This is why it is important to properly understand how the media oper-
ate, their constraints and their needs, in order to maintain good communication with the com-
munities affected in emergency situations.
Progression of the News

The media are notified very early of an emergency situation (sometimes even before the person
responsible for communications or the designated spokespersons) due to the spectacular nature
of an event or by an informant. The coverage of the event is initially careful and factual. Next,
if the event continues or if a cover-up is suspected, the media do a follow-up, find other wit-
nesses and begin an investigation.
Given the goal of trying to make “news” out of something, there can be much sensationalism.
Competition with other media colleagues is strong, but the news can simply die out or, on the
contrary, grow, depending on the importance of the other news of the day. It must be remem-
bered that the majority of the news comes from national or international press agencies, which
resell these subscription services to print or electronic pressrooms. There are also numerous press
conferences that feed the journalists information (more than 10 a day in Montreal) from hun-
dreds of news releases distributed daily on the press wires, without counting the research, inves-
tigations and interviews initiated by the journalists themselves.
How the Media Operate

The media are business corporations (even the state media depend on listener ratings for their
financing). However, they must also be considered as forums for reaching the public, inasmuch
as the journalist is interested in local news and that he/she is provided with good material. The
local, regional and national media will cover or not cover an emergency situation, depending on
the interest of their audience or their readership.
The media coverage differs depending on whether it is the print, electronic or broadcast media
and whether it is an in-depth analysis. Unless you are taking part in a public affairs program, you
must be very concise when giving answers on the airwaves of an electronic medium. The print
media allow the journalists to give more details, but they too have space constraints.
Journalists are generally sympathetic to “the weak and the oppressed” (ecologists belonging to
this category) and are unfavourable to governments, civil servants and company decision-mak-
ers.
The information sources less appreciated by the journalists are public relations personnel, news
releases and press conferences. They prefer direct contacts, information sessions, documenta-
tion and personal research. This must be kept in mind when choosing the spokesperson or the
communication tools and methods.

Chapter 7
Media Constraints
The media have not escaped the job and budget cuts that have been hitting the economy for
some time now. The personnel of the pressrooms is reduced, and journalists must cover sever-
al events during the same day; their movements are tracked, and they have very little time avail-
able to carry out research.
Journalists have very strict and inflexible deadlines. They must produce written or electronic
reports that are limited either by space or by time. They often possess general training and nor-
mally have very little specialized technological and scientific knowledge. Lastly, they must adapt
their reports to the format and the public of the media for which they work.
The recent presence of chains broadcasting 24 hours a day requires a greater replenishment of
news; as a result, journalists are lying in wait 24 hours a day for the scoop that will launch their
careers.
ANNEX 2:
Spokespersons and Risk Communication
Choice and Qualities of a Spokesperson

The choice of a spokesperson constitutes a public commitment to communicate. The spokes-
person represents the organization and demonstrates its concern for communicating with the
public and the media. A single spokesperson is normally preferred, so as to avoid contradictions
and confusion in the messages. The choice of a quality spokesperson fosters a climate of trust.
It might be useful to plan for relief or assistant spokespersons for a given region, for a certain
type of public or to provide specialized information in a related domain (environment, insurance,
health, etc.). In this case, it is imperative that everyone conveys the same message as the prin-
cipal spokesperson.
The assessment of the stakes, or the nature and scope of an emergency situation, will enable
choosing the right spokesperson (generalist, specialist, politician, etc.). It is important to choose
a representative who will guarantee the credibility of the information, without needlessly wor-
rying the target groups, rather than opting for an upper-level hierarchical or political represen-
tative who will give the impression of a large-scale crisis when such is not the case. The person
chosen must be trustworthy, competent and bilingual. According to Dr. Powell, the credibility of
the spokesperson was recently evaluated according to four criteria, by order of importance:
empathy or kindness at 50%, followed by skill and expertise, honesty and candour, and lastly
commitment and dedication, each counting for 15 to 20%.
Ideally, the spokesperson should be able to summarize information quickly and possess a glob-
al vision of the situation, possess a team spirit, be autonomous, understand how the organiza-
tion works, have good judgment and maturity, possess the appropriate technical and scientific
skills, and be interested, motivated and capable of resisting stress.

Chapter 7
Attitude Toward the Media

In emergency situations, most journalists act very professionally and appreciate working with a
spokesperson who is familiar with his/her dossiers, who has the most complete and recent infor-
mation possible and who does not try to avoid tough questions.
The following attitudes will help to establish a good relationship with the media:
Openness and candour
• Take initiative, as soon as possible.
• Support the coordinator and show solidarity for the actions and decisions of the team.
• Maintain a certain distance, a global vision.
• Avoid speculating on causes and effects.
• In cases where there is uncertainty, adopt the following attitude: “We do not know every-
thing, but we are assuming our duties.”
• Keep in mind the ordinary citizen / go beyond the journalist; do not act as if talking to
peers.
Steadfastness/calmness
• Immediately correct erroneous information.
• Do not feed the controversy.
• Stick to verified information.
Mutual respect
• Favour mutual respect over mistrust toward the media.
• Take into account media constraints.
• Put yourself in the place of the media (examples, analogies, metaphors).
• Give special attention to veteran journalists (specialized journalists often relay information
to less-experienced ones).

Chapter 7
ANNEX 3: Communication Activities and Tools

Risk Communication and Emergency Situation Communication
MEDIA RELATIONS
Types Uses Advantages and drawbacks
Media • In risk This communication tool is used to inform the press agencies, or selected
communication media, of events to come. The advisory can, for example, be used to
advisory
• During an announce a press conference.
emergency
• After an
emergency
Press • During an To make the work of the media easier, there should, ideally, be a reserved yet
centre emergency separate area for them, as close as possible to the accident location or the
Coordination Centre. This area can be equipped with telecommunication
devices, office supplies and informative material. This area will also serve as an
accreditation area for the media when organized visits of the site take place.
News • In risk Thanks to its standardized presentation, the news release is the ideal basic
release communication tool. It is sometimes used to summon the media to a press conference, but
it is particularly useful for transmitting information that must be broadcast to
the general public.
• During an The news release is an information link with the public, which allows ensuring
emergency the uniformity of the information broadcast by all the media and transmitting
it to everyone, at the same time, so as to inform them on the development of
the situation and on the measures to take.
It is important, during an emergency, to properly identify the news releases,
either by numbers or by date and time, in order to avoid any confusion. It is
also very helpful to prepare an advance type of news release to which infor-
mation specific to the emergency could be added. Sending out news releases
quickly can be crucial for avoiding rumours and panic.
During an emergency, coordination between responders is essential in order
to avoid contradictions due to inadequate information updates. It is also
important to determine who will grant prior broadcast approval so as to not
unduly delay sending out the news release.
It must be remembered that the news release is no substitute for direct con-
tact with the public. When possible, the latter type of communication is there-
fore preferred.
• After an The news release is essential for transmitting information on the recovery
emergency measures, as well as for confirming the status of the situation.

Chapter 7

MEDIA RELATIONS (cont.)
Press • In risk The media are called to a press conference when it is important to give certain
conference communication details that it is preferable to deliver verbally. The media is not summoned sim-
ply to listen to the reading of a news release. Summary information elements
already broadcast by a news release will be supported here by visual presenta-
tions, an information envelope will be handed out, and it will be possible, after
listening to the spokespersons, to ask questions.
It can be beneficial to arrange for a moderator to make the introductions,
direct the questions and responses to the right persons and ensure that the
planned timetable for the press conference is respected.
• During an During an emergency, the press conference can bring together the principal
emergency spokesperson and the representatives of the main agencies involved to update
the situation. Previously prepared texts will allow sharing the broadcast of infor-
mation, depending on the skills of the responders and the experts, and will form
the subject of a consensus where possible.
The presence of a moderator can be useful, as can the introduction of visual ele-
ments.
• After an The press conference facilitates, via the media, the transmission of information
emergency on recovery measures and an assessment of the current situation.
Interview • In risk Before choosing this method of risk communication, it is important to evaluate
communication its advantages and drawbacks, not only regarding the material to be transmit-
ted, but also regarding the capability, skill and credibility of the person who will
transmit the information. This type of contact, which is more personal and
which can ultimately directly affect the citizens, can have a very big impact. It
must be given serious consideration.
• During an The interview must be granted only after a proper, yet quick, assessment of the
emergency nature of the event, the message to be sent and the concerned public.
• After an Answers to frequently asked questions during emergency situations will be
emergency anticipated here.
Press • During an This is a less formal press conference, whose goal is to reestablish a fact, trans-
briefing emergency mit timely information or answer questions from the media. The press briefing
can be held near the site of the event in order to allow the electronic media to
take pictures.
It can be used to transmit urgent information, make daily updates on the status
of the situation or deal with precise questions.

Chapter 7

MEDIA RELATIONS (end)
• In risk
Press communication
A regular review of what is published and broadcast by the media allows an
review evaluation of the capacity of the communication tools used, as well as how
• During an the broadcast message is processed. It will then be possible to adjust the
emergency communications accordingly and advise the responders regarding the impact
• After an of their decisions.
emergency
Information • In risk It may be advantageous to meet limited media groups (e.g., specialized jour-
session communication nalists) to communicate more specialized information or facilitate greater
understanding of the subject.
Site • During an A visit to the disaster site can be organized for all the journalists, if possible, or
visit emergency for a limited group, depending on the size of the event. This visit will allow
reporting and especially picture taking. Strict accreditation and control must be
arranged, so as to ensure the safety of everyone involved.

Chapter 7

DIRECT CONTACTS
Public • In risk This method of meeting the citizens to speak to them in person and exchange
assembly communication views with them allows both establishing the credibility of the lead agency and
• During an reassuring the public as needed.
emergency The meeting should be properly prepared (clear agenda, verified and approved
• After an texts, visual elements, informative documents, responders chosen for their per-
emergency sonality and their abilities, simulation for the responders, etc.). The hiring of a
credible moderator should be arranged, as well as a question period. As need-
ed, individual meetings can be organized to clarify points that are pending.
Information • During an Depending on the size and length of the emergency, an information centre can
centre emergency be set up as a reference point for the public, who will be informed of the cen-
tre’s location and be able to visit it to obtain the most recent published informa-
tion or to meet a clerk who will find the answers to their questions. In case of
the evacuation and shelter of those directly affected by the emergency, this
centre will be very useful for maintaining links between families.
Telephone • During an During an emergency, telephone response is the first tool that will be used.
contacts emergency Indeed, the automatic reaction of the citizens or the responders will be to use
the telephone to obtain information. It is therefore important that the persons
responsible for the telephone response be mobilized the moment the emer-
gency occurs. As well, the wording of the message to be sent must be clear
and updated regularly. It is obvious that, depending on the nature of the emer-
gency, supplemental and replacement personnel should be planned.
Organization • In risk It can be very beneficial to organize specific events, or to take advantage of
of communication holding such events, to transmit information on risks. This event can be break-
specific fast talks, exhibitions, industrial visits, etc. Depending on the situation, stands
events will be prepared, information publications will be distributed and visual presen-
tations will be planned.
Participation • In risk As a JCC is by definition a group of representatives from municipalities, busi-

in a JCC (Joint communication nesses, agencies and citizens, participating in the risk analysis, prevention,
Coordinating response and communication process enables direct contact between respon-
Committee) ders, experts and citizens, so as to allow for a better understanding of the risks
and their consequences. Through a JCC, a greater awareness can be undertak-
or the en, thus allowing the elimination of the greatest number of possible risks.
equivalent

Chapter 7

DIRECT CONTACTS (end)
Training • In risk Training sessions, which are intended for responders in emergency measures,
session communication are the perfect opportunity to make the responders aware of the existing risks
• After an and the measures put in place to remedy them, as well as the importance of
emergency their contribution as informal communicators.
Information • In risk It can be beneficial to meet citizens’ groups or particularly concerned individuals
session communication to share with them more detailed or specialized information and allow a greater
• During an understanding of the subject.
emergency Outside the context of an emergency situation, it can also be worthwhile to
offer information sessions in the schools, for example.
Public • During an Depending on the type of risk, the affected population can be informed in
alert emergency different ways. Whether it consists of a door-to-door, megaphone, telephone
system call or siren approach, the use of an alert system must be subjected to a well-
planned procedure, and the significance of the messages, as well as the
instructions to follow, must have been properly communicated to the citizens
beforehand.
Information • In risk Organizing specific events that have a link with risk management will provide
tour or communication an opportunity to establish information stands on the risks, their consequences,
stand in and the safety measures put in place and to develop, as well as the safety
public areas behaviour to adopt in case of an emergency situation.

Chapter 7

INFORMATION TOOLS
Posters • In risk The use of public notices (posters) is very helpful for sending notifications and
communication instructions to the population.
• During an The posters must be designed in a way to attract attention, with a visual
emergency reminder of the event in question. During an emergency, it is more effective to
always display the posters in the same area.
Stickers • In risk In promoting public awareness of the risk consequences, stickers and display
and display communication magnets are practical reminders to distribute to the citizens.
magnets
Data • During an It is important to put together and update a data bank concerning the agen-
banks emergency cies and businesses and their respective roles, the manufactured or stored sub-
stances, the activities, the background, the economic consequences, the num-
ber of jobs, etc. This bank could also store maps and photographs that could
be used to illustrate the site or to provide information on the nature of the
accident.
Such a data bank facilitates the research of the responders and the media and,
by its very existence, has an impact on the public’s sentiments of safety and
understanding. These data banks will be drawn upon for information to
include in the press envelopes.
Resource • During an An updated directory of the coordinates of the responders and the potential
directory emergency suppliers is an invaluable work tool in emergency situations. It must be kept
within arm’s reach, for, in the event that the anticipated sites for managing the
disaster are not accessible, this directory will allow the responder to work in
another location and use other response resources.
Information • During an Rapid and regular meetings with certain responders will allow the updates
briefing emergency and transmission of information necessary to continue the response, as well
as a reevaluation of the pertinence and allocation of tasks.
Information • In risk An information bulletin published regularly will allow making the different
bulletin communication awareness elements of the Communication Plan accessible and will enable
maintaining contact with the target public.
• During an The bulletin allows broadcasting periodic information to those directly affected
emergency by the emergency on the development of the situation. The bulletin must be
available in a known area or be part of a personalized distribution. It also
enables maintaining a reassuring contact with the public. The production for-
mat and mode of the bulletin must be flexible to adapt to strict timetables.

Chapter 7

INFORMATION TOOLS (cont.)
Internal • In risk Whether it is a municipality, a company or an agency, the internal bulletin

bulletin communication allows linking personnel to the risk communication process and making them
aware of the importance of their role. This aspect should not be neglected in
the Communication Plan, as the personnel, in addition to being directly con-
cerned by the risk consequences, are informal communicators of the organi-
zation.
Circulars • In risk An information sheet aimed at a target public, delivered door-to-door or dis-
or communication tributed at the Information Centre, will be effective for transmitting the infor-
information mation quickly or inviting the public to a meeting.
sheets
• During an This information tool allows dealing with certain specific aspects (health, envi-
emergency ronment, insurance, etc.) and ultimately putting together a complete informa-
tion package.
Internal • During an The internal communiqué will be helpful for municipalities, businesses and
communiqué emergency agencies alike for transmitting information or instructions to employees or for
providing updates on the situation.
Target • In risk Awareness is always made easier by direct contact with the target groups or
correspondence communication individuals, whether to inform them or to invite them to an event. This method
could be used to contact businesses, agencies, populations at risk (schools, sen-
iors’ residences, etc.) or individuals by a letter signed by a person whose credi-
bility is known.
Leaflets • In risk Unless an emergency situation lasts a very long time, there is no point in think-
communication ing about publishing leaflets during an emergency, given the production delays.
• During an It will therefore be wise to prepare leaflets in advance that contain instructions
emergency to follow in particular situations, or other helpful information. These documents
will promote awareness of the risks before the emergency and will be especially
useful for quickly informing those individuals directly affected, the general pub-
lic and the media at the time of the emergency.
Documents • During an In order to be properly understood by those directly affected by the emergency
for the emergency or by the media, it is important to put into layman’s terms the technical infor-
layman mation to be communicated. In many cases, the analysis of the risks and conse-
quences has been done beforehand. Accordingly, it is beneficial to prepare
these documents in advance, during stress-free periods. These documents
could be part of those that will be handed out during press conferences.
Standard • During an A registry of documents, such as news releases, public notices or media advi-
documents emergency sories, can be prepared beforehand, thus facilitating the work for those less
(pre-authorized accustomed to preparing such publications during an emergency situation.
information )

Chapter 7

INFORMATION TOOLS (end)
PowerPoint • In risk During press conferences, information sessions or public assemblies, the infor-
presentation communication mation to transmit can be more easily understood if a visual presentation is
• During an relied upon. The content must be carefully validated, especially if someone
emergency who is not very familiar with the subject at hand prepares the presentation.
Paid • In risk Paying for a newspaper ad or airtime is the only guaranteed way of publishing
advertisement communication a general interest message, all while retaining control of the message and its
presentation.
Web site • In risk This communication tool is more and more accessible to the general public,
and communication and of course to the media. It might be worthwhile to distribute information
e-mail awareness documents via the Internet and thus open another exchange forum
with the citizens.
Tables, • In risk These visual elements are excellent tools not only for explaining the different
maps, communication aspects of the risk consequences, but also, in emergency situations, for illustrat-
diagrams, • During an ing the scope of the disaster and providing the necessary explanations.
photographs emergency These tools put into perspective data on the event. They allow locating and/or
and archived viewing the event. They thus facilitate understanding.
films

Chapter 7
ANNEX 4:
Tip Sheet for Media Relations
in Emergency Situations
• Properly specify the goal of the interview and the meaning of the question.
• Take the time to identify the journalist and the media.
• Ask or anticipate if other persons will be interviewed.
• If you are not able to answer right away, find out the story deadline and call back as soon as
possible.
• Everything that you say can be repeated: there is no “off the record”; make sure that the
meaning of what you are saying is clear.
• Imagine that you are talking to someone who is indifferent and poorly informed on the sub-
ject: appear convincing, interesting and sure of yourself without being pretentious.
• Do not respond to aggressiveness by a hostile answer; remain calm, polite and instead point
out the positive aspects.
• Give short and precise answers; wait for the questions.
• Do not hesitate to pause to think before answering.
• Point out if essential information has not been given.
• On television, look after your appearance, without being uptight (avoid three-piece suits, the
colours black and green, eccentric fabrics; opt for simple hairstyles and the colour blue;
avoid flashy jewellery or makeup, as well as hair in the face).

Chapter 7
ANNEX 5:
Bibliography
Baker, Frank. “Risk Communication about Environmental Hazards.” Journal of Public Health
Policy, Autumn 1990.
Canada. Privy Council Office. Risk Management for Canada and Canadians: Report of
the ADM Working Group on Risk Management. [Ottawa]: Privy Council Office, 2000, 31 pp.
URL: http://www.pco-bcp.gc.ca/
Covello, V.T. [et al.] Risk Communication. Washington, D.C.: Conservation Fund, 1986.
Covello, V.T. and Allen, F. Seven Cardinal Rules of Risk Communication. Washington, D.C.:
U.S. Environmental Protection Agency, Office of Policy Analysis, 1988.
Covello, V.T. “Trust and Credibility in Risk Communication.” Health and Environment Digest,
April 1992, 6 (1), pp. 1-3.
Covello, V.T., Fischhoff, B., Kasperson, R.E., and Morgan, M.G. 1993. “Comments on
‘The Mental Model‘Meets’The Planning Process.’” Risk Analysis, 13, p. 493.
Denis, Hélène. Comprendre et gérer les risques sociotechnologiques majeurs. Montréal: Édi-
tions de l’École polytechnique de Montréal, 1998, 342 pp.
Lagadec, Patrick. La gestion des risques. McGraw-Hill, 1991.
Levine, A. Love Canal: Science, Politics and People. Lexington, Mass., 1982.
Nelkin, Dorothy. “Communicating Technological Risk: The Social Construction of Risk
Perception.” Annual Review of Public Health, 1989, pp. 95-113, New York.
Powell, Douglas. “Risk Communication—Hog Environmental Management Strategy.” In:
Proceedings for the Joint Canadian Pork Council and Agriculture and Agri-Food Canada
Workshop on Hogs and the Environment. [Ottawa]: Agriculture and Agri-Food Canada, 2001,
21 pp. http://res2.agr.ca/initiatives/manurenet/en/hems/powell.html
Powell, Douglas and Leiss, W. Mad Cows and Mother’s Milk: the Perils of Poor Risk
Communication. Montréal: McGill-Queen’s University Press, 1997, 308 pp.
Protess, D.L. [et al.] “The Impact of Investigative Reporting on Public Opinion and
Policymaking.” Public Opinion Quarterly, 51, 1987, pp. 166-185.
U.S. National Research Council. 1989. Improving Risk Communication. Committee on
Risk Perception and Communication. Washington, D.C.: National Academy Press, 332 pp.

Evaluating the Goal
of the Objectives
Chapter
8 75
Chapter 8
A fter having implemented the tools to allow us to prevent accident risks and develop a
corresponding emergency plan, it is evident that we must evaluate the goal of our objectives.
Everyone works in a spirit of collaboration and consensus in order to design and promote ways
of improving prevention, preparedness and response (PPR) in Quebec. To this end, MIACC has
created questionnaires intended for sites and communities.
The main objectives of the Partnerships Toward Safer Communities initiative are to:
• increase awareness of the risks associated with hazardous substances; and
• increase the quality of joint emergency PPR activities by local authorities and plant site per-
sonnel in communities with hazardous installations—those that manufacture, use, handle,
store, make ready for transport or dispose of hazardous substances.
An integrated emergency PPR program is highly recommended in communities that have haz-
ardous installations or those that are situated on dangerous goods transportation corridors.
Communities with such a program are generally better prepared and more capable of effective-
ly responding to disasters—human-made or natural. To facilitate the development of such a pro-
gram requires that members of the community and its industry work together in a single forum
of cooperation and consensus. This forum is referred to as a Joint Coordinating Committee
(JCC).
Ideally, the JCC should be a forum open to all those with a vested interest in the community’s
public safety, plant safety and environmental protection. Representatives of each of the follow-
ing organizations will help the community to raise its current level of PPR:
• emergency services organizations (fire, police, ambulance, public works);
• regional or community emergency measures coordinators;
• elected officials;
• medical services (public health, emergency services, hospitals);
• industry representatives;
• major transportation companies (rail, trucking, marine, warehousing, pipelines);
• non-governmental organizations with emergency response capability, such as Canadian Red
Cross, St. John’s Ambulance and the Salvation Army;
• public and public advocacy groups;
• media;
• provincial emergency measures coordinators and environment officers; and
• regional directors from relevant federal departments, such as Emergency Preparedness
Canada and Environment Canada.
Benefits of Joint Emergency Preparedness

An integrated emergency preparedness delivers a number of benefits to communi-
ties, including:
• ensured the safety of the public, workers and emergency responders;
• reduced property and environmental damage;
• increased public confidence in authorities representing industry and the public sector;
• increased greater confidence of public authorities toward industry;
• increased availability of vital emergency information for the public, media and emergency
response;
• increased availability and quality of resources to mitigate emergencies; and
• provision of a voice to all stakeholders in the PPR process.

Chapter 8
About the Site Self-assessment Tool

The questions contained in the Site Self-assessment Tool will help your site to establish a base-
line of its current PPR status as well as assist those involved in identifying key areas for improve-
ment.
Through widespread consultation with major industry sectors and governments at all levels, a
consensus-based agreement has been reached on what prevention and preparedness measures
should be expected from the operators of hazardous installations. Prevention should meet one
of the recognized systems of process safety management, while preparedness should comply
with national standard CAN/CSA-Z731 Emergency Planning for Industry as described in Chapter
6 of this current guide on the development of an emergency measures plan.
The questions on the prevention of major industrial accidents have been developed from the
process safety management guide of MIACC (Chapter 4), which is based on an approach
designed by the Center for Chemical Process Safety (CCPS) of the American Institute of
Chemical Engineers. Although CRAIM has chosen the CCPS approach, other approaches may
also be adopted. The questions presented here should also be relevant for companies using
other methods.
The questions have been developed to assess the current level of awareness and use of the
major accident prevention/preparedness techniques outlined in the 12 elements of process safe-
ty management. The techniques are important for proper control of major hazards in any facil-
ity that manufactures, uses, stores, makes ready for transport or disposes of hazardous sub-
stances. A number of these activities support the need for integrated emergency prevention,
preparedness and response among your site and its surrounding community. This is generally
facilitated through the establishment of a Joint Coordinating Committee (JCC) at the local level.
The Site Self-assessment Tool was recently pilot-tested at a number of sites across Canada. It
was generally completed in two to four hours. Recipients indicated that the use of the tool was
a positive experience that helped site managers identify vulnerabilities in their existing systems
for control of major accident hazards. The pilot test also helped to confirm the need for more
communication and follow-up on major hazard control techniques and indicated some likely pri-
orities for guidance and support.
How to Use the Site Self-assessment Tool

The first objective of this tool is to determine if certain specific activities, deemed necessary for
an effective community prevention, preparedness and response program, are carried out.
A separate questionnaire should be used for each area evaluated, as the results may vary great-
ly from one site to the next, even within the same company. This form can be reproduced as
needed.
Please follow the instructions below:
• Complete the general information page on the site. To do this, you must determine which
hazardous substances are found on the site in quantities exceeding the limits. Please refer to
the lists in Annex 3 of the guide. In the appropriate areas, you must specify the substances
that, at any given moment, are found on the site in quantities exceeding the limits. Please note
that the limits represent the total quantity on the site, and not the quantity in a given contain-
er.
• For questions on the emergency preparedness of the site, specify which activity is carried out
(Yes) and which activity does not take place on the site (No). Mark an X in the appropriate
column to the right of each question. You may provide additional comments at the end of the
document.

Chapter 8
• For questions on process safety management, at three levels, answer A, B, C or D by marking

an X in the appropriate column to the right of each question, in order to specify the level of
understanding and use of this technique on the site, according to the following criteria:
A . . . . . . . . .Widespread and comprehensive use wherever significant hazard

potential exists.
B . . . . . . . . .Moderate use, but coverage is uneven from unit to unit or not
comprehensive in view of potential hazards.
C . . . . . . . . .Appropriate personnel are aware of this item and its application,
but little or no actual use.
D . . . . . . . . .Little awareness or use of this item.
• When you are done, mark an X on the second general information page on the site to indi-
cate the overall grade obtained (for example, to reach the Essential level, you must have
answered A to all the questions for this level; to reach the Enhanced level, you must have
answered A to all the questions for the Enhanced and Essential levels, etc.).
• Authorities from your community will perhaps use a community self-assessment tool, allow-
ing the evaluation of the community’s status in terms of joint prevention, preparedness and
response. When these authorities conduct the self-assessment, they must communicate with
your site in order to find out its status, determined with the help of the site self-assessment
tool. Please make sure that this information is transmitted to the community and that a site
representative participates in a Joint Coordinating Committee.
Note:
The site self-assessment tool is intended to help sites evaluate the extent to which they are in
control of major risks. Accordingly, all operations on and off the site, capable of greatly influenc-
ing the likelihood or severity of a major industrial accident involving hazardous substances,
should receive priority treatment. Please ask for help if you are unsure of how to proceed.

Chapter 8
SITE SELF-ASSESSMENT TOOL

General Information
Name of company:
Location of site:
Name of site:
No. and street:
City:
Province:
Postal code:
Latitude:
Longitude:
Approximate number of employees on the site
(including regular contractors):
Hazardous substances on-site on the list
according to Annex 3 of the guide:
Substances kept on the site exceeding the limit:
Site Emergency Preparedness
Requirements to achieve the ESSENTIAL level
YES NO
1. Is there a documented emergency plan? ❑ ❑

2. Has this plan been tested? ❑ ❑
3. Is the site involved in a community preparedness committee? ❑ ❑
4. Has a representative from the site been designated
as spokesperson in case of emergency? ❑ ❑
5. Does the community know the emergency response
capability and resources of the site? ❑ ❑
6. Is there a community information program in place
on the risks posed by the site and the measures
to take in case of emergency? ❑ ❑

Chapter 8
Additional requirements to achieve the ENHANCED level
YES NO
7. Have the requirements in case of emergency been

communicated to local authorities in order to include
them in the community emergency plan? ❑ ❑
8. Has the spokesperson of the site received proper
training on the information broadcast strategy
and procedure in case of emergency? ❑ ❑
9. Does the site participate in a joint emergency training
program with the community? ❑ ❑
If not, please explain:
Additional requirements to achieve the EXCELLENT level
YES NO
10. Have documented mutual aid agreements

been concluded? ❑ ❑
If not, please explain:
11. Has a documented emergency plan, aiming to minimize

disruptions in the community, been prepared? ❑ ❑
Current General Status of
the Process Safety Management
Based on the results of the self-assessment questionnaire, indicate whether your site has
reached one of the following achievement levels (for example, to qualify for the essential level,
all questions for that level must be answered with an “A”; for the enhanced level, all questions
for enhanced and essential levels must be at “A,” etc.).
In progress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ❑
❑
Essential . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Enhanced . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ❑
❑
Excellent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Site Representative (for the JCC, if in place)

Name:
Title:
Area:
Tel.: Fax:
E-mail:

Chapter 8
Self-assessment of Current Status
Process Safety Management

Requirements to Achieve the ESSENTIAL Level
For each survey question, indicate the level of awareness and use at the site by
marking the appropriate box, based on the following:
potential exists.
A B C D
1. Accountability: objectives and goals

a) Are the responsibilities clearly defined and
communicated, with those responsible held
accountable? ❑ ❑ ❑ ❑
b) Is there a system for control of contractor
operations? ❑ ❑ ❑ ❑
a) Are the safety, health and environmental
hazards of materials on-site clearly defined? ❑ ❑ ❑ ❑
b) Is there current comprehensive documentation
covering the process operations basis, including
both normal and abnormal conditions? ❑ ❑ ❑ ❑
3. Process safety review procedures for capital projects
a) Are all project proposals for new or modified
facilities subjected to documented hazard
reviews before the projects are approved
to proceed? ❑ ❑ ❑ ❑
b) Are systems established to ensure that
the facility is built as designed? ❑ ❑ ❑ ❑
c) Is there an effective link between design
modifications and operating procedures? ❑ ❑ ❑ ❑

Chapter 8
A B C D

a) Is there a system, conducted by competent
personnel, to identify and assess the process
hazards from materials present at this site? ❑ ❑ ❑ ❑
b) Are corrective actions defined and
implementation followed up? ❑ ❑ ❑ ❑
c) Are the above items formally documented? ❑ ❑ ❑ ❑
a) Is there a system to manage any modification to:
• technology/materials/products? ❑ ❑ ❑ ❑
• equipment/controls/software/
process operations? ❑ ❑ ❑ ❑
b) Does the system cover temporary, experimental
and emergency work? ❑ ❑ ❑ ❑
c) Does the system ensure that all changes, including
operating procedures, are documented prior to
commissioning, startup, shutdown or
implementation of the change? ❑ ❑ ❑ ❑
d) Are the personnel informed of the change and
given any necessary training before they are
expected to operate the facility? ❑ ❑ ❑ ❑
6. Process and equipment integrity
a) Is there a system to ensure that critical equipment:
• is adequately specified? ❑ ❑ ❑ ❑
• is designed and fabricated to specifications? ❑ ❑ ❑ ❑
• is correctly installed and commissioned? ❑ ❑ ❑ ❑
• is operated within design limits? ❑ ❑ ❑ ❑
• is correctly maintained? ❑ ❑ ❑ ❑
b) Does the system cover:
• raw material suitability? ❑ ❑ ❑ ❑
• the compatibility of construction materials? ❑ ❑ ❑ ❑
• fabrication/installation and inspection procedures? ❑ ❑ ❑ ❑

Chapter 8
A B C D
• prevention/predictive maintenance
procedures? ❑ ❑ ❑ ❑
• critical instrument programs? ❑ ❑ ❑ ❑
c) Are written operating procedures in place and
accessible, covering startup, shutdown,
normal and emergency conditions? ❑ ❑ ❑ ❑
d) Are the systems established enforced for:
• confined space entry? ❑ ❑ ❑ ❑
• safe control of maintenance/project work,
including by contractors? ❑ ❑ ❑ ❑
• lock/tag out to prevent unplanned release
of materials? ❑ ❑ ❑ ❑
• opening potentially hazardous lines or
equipment? ❑ ❑ ❑ ❑
• control of hot work? ❑ ❑ ❑ ❑
7. Human factors
Is there a system to consider, when designing
equipment or operating procedures, the potential
for human error? ❑ ❑ ❑ ❑
8. Training and performance
a) Is there a system to identify personnel knowledge
and skill requirements for the work to be done? ❑ ❑ ❑ ❑
b) Are training programs designed to ensure that
requirements of (a) are met and maintained? ❑ ❑ ❑ ❑
c) Is competence assessed after training is given? ❑ ❑ ❑ ❑
9. Incident investigation
a) Is there a documented program to report
and investigate all significant accidents and
incidents (spills, leaks, fires, injuries, etc.)? ❑ ❑ ❑ ❑
b) Are basic causes and corrective actions
determined? ❑ ❑ ❑ ❑
c) Does the system document actions required,
responsibilities and follow-up? ❑ ❑ ❑ ❑

Chapter 8
A B C D
10. Company standards, codes and regulations

Is there a system to ensure compliance with
current laws and regulations applicable to site
operations? ❑ ❑ ❑ ❑
11. Audits and corrective actions
Is there a basic audit/inspection system to assess
whether the items covered at this level are indeed
being done and are effective? ❑ ❑ ❑ ❑
12. Enhancement of process safety knowledge
Not required at this level

Chapter 8

Requirements to Achieve the ENHANCED Level
potential exists.
A B C D

a) Is there a policy statement expressing
management’s commitment to process
safety/loss prevention? ❑ ❑ ❑ ❑
b) Are there formal systems for handling
exceptions? ❑ ❑ ❑ ❑
Is there current comprehensive documentation
covering the process and equipment design basis? ❑ ❑ ❑ ❑
a) Does the review consider plant siting and layout? ❑ ❑ ❑ ❑
b) Are fail-safe features/redundancy considered? ❑ ❑ ❑ ❑
c) Is a pre-startup review conducted? ❑ ❑ ❑ ❑
Which of the following techniques form part of the
site risk management system (must use at least
one to achieve Enhanced status)
a) “What-if” and/or checklists ❑ ❑ ❑ ❑
b) Failure modes and effects analysis (FMEA) ❑ ❑ ❑ ❑

Chapter 8
A B C D
c) Dow Fire and Explosion Index (FEI) or
Chemical Exposure Index (CEI) ❑ ❑ ❑ ❑
d) Hazard and operability analysis (HAZOP) ❑ ❑ ❑ ❑
e) Fault tree analysis ❑ ❑ ❑ ❑
No additional requirements at this level

Are operating procedures reviewed on a defined
frequency and updated as necessary? ❑ ❑ ❑ ❑
7. Human factors
Are the following human factors taken into account
in the design and operation of the facility:
a) Compatibility of interface between
operator and process/equipment? ❑ ❑ ❑ ❑
b) The balance between administrative
controls (e.g., systems and procedures)
and hardware controls? ❑ ❑ ❑ ❑
a) Is there a system of establishing initial
qualifications to ensure that prospective
employees have the aptitude and base
knowledge/skills that, with appropriate
training, will enable them to do the job? ❑ ❑ ❑ ❑
b) Is the formal and periodic training
conducted in:
• Operating and maintenance procedures? ❑ ❑ ❑ ❑
• Process hazards and designated substances? ❑ ❑ ❑ ❑
• Emergency preparedness/release mitigation? ❑ ❑ ❑ ❑
• Work permit systems? ❑ ❑ ❑ ❑
• Personal protective equipment? ❑ ❑ ❑ ❑

Chapter 8
A B C D
a) Does the documented program to report
and investigate all significant accidents and
incidents also cover near-misses? ❑ ❑ ❑ ❑
b) Are investigation reports communicated
to all appropriate personnel throughout
the organization? ❑ ❑ ❑ ❑
Is there a system to ensure compliance with
current laws and regulations applicable
to site operations? ❑ ❑ ❑ ❑
Is there a system for formally assessing:
a) compliance with laws and regulations? ❑ ❑ ❑ ❑
b) process safety management systems
(to ensure that company policies,
procedures, etc. are being followed)? ❑ ❑ ❑ ❑
c) safety and health of employees and
contractors? ❑ ❑ ❑ ❑
d) effects of the facility on the environment
and the community? ❑ ❑ ❑ ❑
Do you have a search facility you can use
to find information on process safety, either
in the company or via external means, such
as a reference library, the Internet, etc.? ❑ ❑ ❑ ❑

Chapter 8

Requirements to Achieve the EXCELLENT Level
potential exists.
A B C D

a) Is accountability continuous (i.e., regardless
of changes in personnel, production
schedules, organizational structure, etc.)? ❑ ❑ ❑ ❑
b) Does the system ensure effective
implementation of all items covered by
the questions under Element 1—Accountability:
objectives and goals? ❑ ❑ ❑ ❑
a) Is there current comprehensive
documentation covering the basis for
the protective systems design (including
consequences of deviation)? ❑ ❑ ❑ ❑
b) Is all the information on hazards of materials
on-site, operations basis, process and equipment
design basis, and protective systems design basis
communicated to and understood by those who
need it? ❑ ❑ ❑ ❑
a) Does the company have its own engineering
standards that are current and maintained? ❑ ❑ ❑ ❑
b) Is there a system to manage deviations from
standards? ❑ ❑ ❑ ❑

Chapter 8
A B C D

a) Which of the following techniques form part
of the site risk management system (must use
at least one to achieve Excellent status)?
• “What-if” and/or checklists ❑ ❑ ❑ ❑
• Failure modes and effects analysis (FMEA) ❑ ❑ ❑ ❑
• Dow Fire and Explosion Index (FEI) or
Chemical Exposure Index (CEI) ❑ ❑ ❑ ❑
• Hazard and operability analysis (HAZOP) ❑ ❑ ❑ ❑
• Fault tree analysis ❑ ❑ ❑ ❑
b) Is there a system for periodic hazard review? ❑ ❑ ❑ ❑
Is there a system to manage any modifications
to individual/organizational responsibilities? ❑ ❑ ❑ ❑
Are facilities designed and built to engineering
standards and recognized and generally
accepted good engineering practice? ❑ ❑ ❑ ❑
7. Human factors
Is formal assessment of human error
potential taken into account in the design
and operation of the facility? ❑ ❑ ❑ ❑
a) Are instructor qualifications defined
and competence tested? ❑ ❑ ❑ ❑
b) For each of the Essential, Enhanced
and Excellent levels, are all items
covered under Element 8—Training
and performance formally documented? ❑ ❑ ❑ ❑
Does the feedback include lessons learned,
both from within the company and elsewhere,
and actions taken to eliminate future incidents,
and are these formally incorporated into
corporate standards? ❑ ❑ ❑ ❑

Chapter 8
A B C D

Is there a system for monitoring emerging
development in codes and standards likely
to be applicable to site operations? ❑ ❑ ❑ ❑
Is there a system for benchmarking audit
processes and techniques against best industry
practice? ❑ ❑ ❑ ❑
Is there a system for staying abreast of changes
in safety requirements, developments in safety
systems and technology, etc., regarding:
• Materials and processes used on-site ❑ ❑ ❑ ❑
• Process industries, etc., in general ❑ ❑ ❑ ❑
Additional Comments or Remarks:

Below you are invited to provide any additional details of your community’s PPR program. This
may include expansions of any of the questions (and their sub-components) listed on the previ-
ous pages or details of county, or region-wide PPR programs that the site participates in (iden-
tify membership in Community Awareness and Emergency Response (CAER) or other commit-
tees). Please indicate which question the comment pertains to.

Chapter 8
About the Community Self-assessment Tool
T he intent of the Community Self-assessment Tool is to help communities assess commu-

nity prevention and preparedness in relation to potential releases of hazardous substances.
There are many benefits of communities adopting an all-hazards approach to emergency pre-
paredness. Recent studies have shown, however, that most communities have not adequately
dealt with the risks associated with potential releases of hazardous substances. This self-assess-
ment will help your community in this regard by identifying areas for improvement in the haz-
ardous substances component of an all-hazards approach.
The questions contained in the Community Self-assessment Tool will help your community to
establish a baseline of its current PPR status as well as assist those involved in identifying key
areas for improvement. Each question has been developed to identify the presence of activities
that are seen as being crucial for a community that is at risk from the hazards associated with
hazardous substances. At the heart of these activities is the need for coordinated emergency
prevention, preparedness and response (PPR) among local authorities and the community’s
industry. This is generally facilitated through the establishment of a Joint Coordinating
Committee (JCC) at the local level.
Completing the Community Self-assessment Tool

Each question of this Community Self-assessment Tool has been developed and reviewed by
specialists in community preparedness from across Canada. They have been designed to elicit a
No, In Progress, or Yes response. It is up to the community’s elected officials and site rep-
resentatives to evaluate and monitor the quality of joint community/industry emergency pre-
paredness.
The primary function of the tool is to determine the presence of a particular activity that is
deemed to be necessary for an effective community PPR program.
The following instructions will help you answer the questions of the self-assessment
tool:
• Study the list of facilities at risk that you determined during your JCC meetings and request
the PPR status of the site as measured with the help of the site self-assessment tool.
• For each question, answer No, In Progress, or Yes, by marking an X in the appropri-
ate column to the right of the question. Explanations are provided for each question.
• After the questionnaire is completed, you will be able to evaluate your emergency prepared-
ness level (Essential, Enhanced, Excellent).

Chapter 8
List of Hazardous Installations

The following list (see page 90) includes the hazardous installations that are confirmed to exist
within your community. This is not an exhaustive list, nor is it an indication of the level of risk
that these installations pose to the community. Many factors affect risk.
The community JCC is encouraged to seek representatives from each of the installations listed
below to participate in joint community/industry emergency prevention and preparedness activ-
ities. As well, the JCC is encouraged to identify additional sites that should be represented on
the committee, to contact these sites and to gain their cooperation and participation in the com-
munity’s PPR program.
Each of the hazardous installations named below is being sent a Site Self-assessment Tool to
measure the prevention, preparedness and response (PPR) capability at the site. A site evaluates
PPR based on the implementation of process safety management and joint preparedness with
its community. The levels that would be reported through the Site Self-assessment Tool are the
same as in the Community Self-assessment Tool—Essential, Enhanced or Excellent. A checkmark
in the first column would indicate that the site is currently working toward the Essential level.
Please contact the listed sites and indicate their reported PPR status in the column adjacent to
the appropriate company name. Fill in or correct any misinformation. Add any additional sites
participating in the initiative, their representative’s name and the status reported in relation to
the Site Self-assessment Tool.

Chapter 8
Example of table to use for the list of facilities at risk
In Progress
Enhanced
Excellent
Essential
Company Representatives

Chapter 8
Guidelines for Assessing

Community Preparedness
1. Joint Coordinating Committee (JCC)

A joint coordinating committee is essential in communities that have either hazardous installa-
tions or dangerous goods transportation corridors. Ideally, it is an open forum for all those with
a vested interest in the activities of the municipality regarding prevention, preparedness and
emergency response. Members of the municipalities and its industrial sector work through such
a forum in a cooperative and consensus-based manner to develop a fully integrated PPR pro-
gram. Guidance for the establishment of this type of committee is contained in the MIACC doc-
ument “Guiding Principles for Joint Community and Industrial Emergency Preparedness” and
the Community Resource Kit. Additional supporting information can be found in the United
Nations Environment Programme Awareness and Preparedness for Emergencies on a Local Level
(APELL) document entitled “A Process for Responding to Technological Accidents,” Chapter 3.
The APELL document calls this group “a co-ordinating group,” but it is essentially the same type
of committee.
2. Designated community emergency measures officer

In larger communities (cities and regional governments), this would usually be a full-time staff
member. In smaller communities, it may be a part-time official or an official with another posi-
tion, for example, a fire chief. However, the individual should be specifically designated by com-
munity officials and should be responsible and accountable for the emergency measures pro-
gram, including the development and maintenance of the community emergency plan. Actual
titles vary but may include disaster services officer, emergency program coordinator, emergency
planner, emergency preparedness officer, etc.
3. Joint community and industry hazard identification

and risk assessment
This is the first step in developing an emergency plan. It is a formal process and is described in
the MIACC “Guiding Principles” document and in Chapter 5 of the APELL document.
4. Community emergency plan

This should be considered a basic emergency plan, which could be used by the community to
respond to any major emergency. This is normally referred to as a generic all-hazards plan.
5. Hazardous substances
These are substances that are identified in List 1, 2 or 3 of the MIACC Lists of Hazardous
Substances.
6. Community Emergency Operations Centre (EOC)

An EOC should be identified and be of an appropriate size for the community control group.
Basic telecommunications equipment is required (phones, fax, radio and Internet). Other mate-
rials necessary for operations should be organized and readily available.

Chapter 8
7. Documented industrial emergency response capability and

resources
Community emergency plans should include a database of all locally available industry resources
such as equipment, materials and specially trained personnel. These lists should include specific
hazard capabilities and call-up agreements and information. This must include appropriate
telecommunications linkages. Emergency response teams should be identified and trained to
deal with each industrial hazard.
8. Community and industry emergency information personnel

These are spokespersons during an emergency. Emergency information is disseminated to the
media and the public. These spokepersons may or may not be the same individuals who deliv-
er the public education program. They should be identified in the community plan.
9. Annual exercise
This is an exercise to evaluate the basic community emergency plan. A variety of exercise sce-
narios are possible, from a paper or table-top exercise to a full-scale field exercise or disaster sim-
ulation.
10. Joint community and industry public education program

This program could include a variety of approaches and products, from town meetings to
brochures. Whatever its format, there should be no doubt that the media and public are aware
of the hazard within their community. The MIACC’s “Guiding Principles” document and
Chapter 4 of the APELL document are both excellent sources of guidance.
11. Enhanced community emergency plan

This level requires a more comprehensive plan, which is scaled to the size of the community.
Detailed guidance is found in the APELL document, particularly in the annexes.
12. Trained community and industry spokespersons

An annex to the main emergency plan should outline how the community would communicate
with the media and the public during an emergency. Spokespersons from the community and
industry should be adequately trained and included in emergency plan exercises.
13. Enhanced community Emergency Operations Centre

Each hazardous installation should have an annex to the community emergency plan and EOC
operating procedures to implement site-specific emergency response plans. This would require
the presence of an industry liaison officer in the community EOC during an emergency.
14. Integrated community and industry emergency

telecommunications system
A specific community/industry emergency telecommunications plan should be developed and
documented, which establishes direct linkages between the community EOC and industry’s
telecommunications hardware systems.

Chapter 8
15. Joint community and industry emergency

preparedness training program
A program should be developed to train community and industry emergency personnel in
accordance with the emergency plan and its specific operating procedures. The program should
include both individual and team training.
16. Comprehensive exercise program

A comprehensive exercise program would include a variety of activities from drills to full-scale
community/industry field exercises. The exercise program should consist of several elements,
which may be spread over a number of years. Some level of exercise should be occurring each
year. The sequence of exercises should be progressive and proceed from the simple to the more
complex.
17. Mutual aid or assistance arrangements

A process should be in place for emergency response assistance from neighbouring communi-
ties and jurisdictions. As well, specialist teams should be identified from industry that could aug-
ment local resources. MIACC’s “Guidelines for Emergency Response Mutual Aid Agreements”
is a good reference.
18. Comprehensive joint community and industry

risk-based public education program
This complete public education program offers a realistic, open and honest perspective on all
the risks that exist within the municipality. The possible incidence of each risk should be formu-
lated. The program contains many facets, particularly activities such as municipality meetings
and education-oriented activities to explain the risks and risk evaluation. As well, this program
covers the role of the media, interviews, educational products, brochures explaining the emer-
gency plans, etc. It is not a simple industrial approach, but instead an integrated program. The
industries should explain the risks and the emergency plans on the site, while the municipalities
should explain the public safety measures off-site. More detailed advice can be found in Chapter
4 of the APELL document.
19. Joint community and industry information centre

This facility is close but separate from the community EOC. Its purpose is to function as a cen-
tre to disseminate emergency information. It is the location where the media is sent (rather than
the EOC). Spokespersons, both community and industry, operate from this location and issue
press releases. It must be appropriately staffed and have the necessary equipment to function,
including telecommunications connections.
20. Joint community and industry risk-based

emergency prevention and mitigation program
Prevention/mitigation are those things that we do to prevent an emergency from occurring and
to minimize its impacts. All of the goals to this point have been preparedness oriented. This
activity deals with steps that could be taken to mitigate the possible impacts of an emergency,
such as improving building standards, establishing buffer zones, etc. It requires an assessment
jointly done by the community and industry, which will identify practical, cost-effective mitiga-
tion strategies. An effective program will involve a long-term strategy. The program should be
reviewed annually.

Chapter 8
21. Risk-based land use planning guidelines

The MIACC publication “Risk-based Land Use Planning Guidelines” is a useful reference.
22. Designated community dangerous

goods transportation routes
The community may establish bylaws that designate specific routes along which dangerous
goods are permitted to be transported through the community. These should be based on a risk
assessment and integrated with community land use planning guidelines and bylaws.
23. Joint community and industry risk-based recovery plans

This is a program of measures that could be taken to assist recovery if an emergency occurs. This
is not a plan for the resumption of business, but rather measures that could be taken to help a
community recover from an industrial accident involving hazardous materials, such as restoring
essential services and opening transportation routes.
24. Joint community and industry review of emergency

measures programs
This is an annual activity that should be completed by the Joint Coordinating Committee. It
should cover all joint prevention, preparedness, response and recovery programs in place with-
in the community.

Chapter 8
COMMUNITY SELF-ASSESSMENT TOOL

General Information
Name of municipality:
Prepared by:
Function:
Tel. No.:
Fax No.:
E-mail:
Head of emergency
measures of municipality:*
Tel. No.:
Fax No.:
E-mail:
*This person is responsible for the development and maintenance of the emergency plan of the municipality. The desig-
nation of this individual may vary: head of emergency services, emergency program coordinator, emergency planner,
head of emergency planning, etc.

Chapter 8
Emergency Prevention
and Preparedness Activities
ESSENTIAL LEVEL
NO IN YES
PROGRESS
1. Joint Coordinating Committee (JCC)

Has your community established a joint
coordinating committee (JCC) where local
authorities and industry representatives work
together to enhance community prevention,
preparedness and response? ❑ ❑ ❑
2. Designated community
emergency measures officer
Has your community designated a community
emergency measures officer who is specifically
accountable for the development and maintenance
of the community emergency plan? ❑ ❑ ❑
3. Joint community and industry hazard
identification and risk assessment
Has your community completed and
documented a joint community/industry
hazard identification and risk assessment? ❑ ❑ ❑
If Yes,
provide year completed: ________________________
4. Community emergency plan

Has your community developed and
documented a community emergency plan? ❑ ❑ ❑
If Yes,
provide year last updated: __________________________
5. Hazardous substances
Does your community emergency plan
specifically address potential releases of
hazardous substances? ❑ ❑ ❑
6. Community Emergency
Operations Centre (EOC)
Does your community have a basic
Emergency Operations Centre (EOC)? ❑ ❑ ❑

Chapter 8
ESSENTIAL LEVEL
NO IN YES
PROGRESS
7. Documented industrial emergency

response capability and resources
Has your community identified and
specifically documented industrial
emergency response capabilities and
resources in the community emergency plan? ❑ ❑ ❑
8. Community and industry emergency
information personnel
Are there designated representatives from both
the community and industry identified in the
community emergency plan who will act as
spokespersons during an emergency? ❑ ❑ ❑
9. Annual exercise
Does your community conduct an annual
exercise to evaluate the community emergency plan? ❑ ❑ ❑
If Yes,
indicate year of most recent exercise: ________________
10. Joint community and industry

public education program
Has your community developed, documented
and undertaken a joint community/industry
public education program to inform the public
and media of hazards in their community and
what to do in case of an emergency? ❑ ❑ ❑
If you answered YES to all the questions numbered 1 through 10,

your municipality has reached the Essential municipality PPR level.

Chapter 8
ENHANCED LEVEL
NO IN YES
PROGRESS
11. Enhanced community emergency plan

Has your community integrated industry
requirements into the community emergency
plan, and are they comprehensive enough to
include telecommunications, alerting of the
public, notification requirements, evacuation,
resource lists, special equipment requirements
and risk-based plans for specific industries? ❑ ❑ ❑
12. Trained community and industry spokespersons
Are the community and industry
spokespersons identified in the emergency
information plan adequately trained on the
strategy and process for disseminating
information during an emergency? ❑ ❑ ❑
13. Enhanced community Emergency
Operations Centre
Does your community have plans in place
to include industry involvement in the
Emergency Operations Centre? ❑ ❑ ❑
14. Integrated community and industry
emergency telecommunications system
Has your community developed, documented
and put in place joint community/industry
emergency telecommunications systems? ❑ ❑ ❑
15. Joint community and industry emergency
preparedness training program
Has your community documented and
undertaken a joint community/industry
emergency preparedness training program? ❑ ❑ ❑

Chapter 8
ENHANCED LEVEL
NO IN YES
PROGRESS
16. Comprehensive exercise program

Has your community undertaken a
comprehensive exercise program to evaluate
joint community/industry emergency preparedness? ❑ ❑ ❑
If you answered YES to all the questions numbered 1 through 16, your municipality
has reached the Enhanced municipality PPR level.

Chapter 8
EXCELLENT LEVEL
NO IN YES
PROGRESS
17. Mutual aid or assistance arrangements
Has your community established and documented mutual
aid or assistance arrangements with neighbouring
communities? ❑ ❑ ❑
18. Comprehensive joint community and industry
risk-based public education program
Has your community developed, documented and undertaken
a comprehensive joint community/industry risk-based public
education program? ❑ ❑ ❑
information centre
Does your community have a joint community/industry
information centrefor the dissemination of information
to the media and the public during an emergency? ❑ ❑ ❑
20. Joint community and industry risk-based
emergency prevention and mitigation program
Has your community developed and implemented a joint
community/industry risk-based emergency prevention/
mitigation program? ❑ ❑ ❑
21. Risk-based land use planning guidelines
Has your community established and implemented
risk-based land use planning? ❑ ❑ ❑
22. Designated community dangerous
goods transportation routes
Has your community designated dangerous goods
transportation routes? ❑ ❑ ❑
risk-based recovery plans
Has your community developed and documented a
community and industry recovery plan? ❑ ❑ ❑

Chapter 8
EXCELLENT LEVEL
NO IN YES
PROGRESS
24. Joint community and industry review

of emergency measures programs
Does your community conduct an annual
joint community/industry review of the
entire community prevention, preparedness
and response program? ❑ ❑ ❑
If you answered YES to all the questions numbered 1 through 24, your municipality
has reached the Excellent municipality PPR level.
Additional Comments or Remarks:

Below you are invited to provide any additional details of your community’s PPR program. This
may include expansions of any of the questions (and their sub-components) listed on the previ-
ous pages or details of county, or region-wide PPR programs that the community participates
in. Please indicate which question the comment pertains to.

Sample Letter
and Instructions to Companies
1
Annex
107
Annex 1
Sample Letter
Date (day – month – year)
(Name)
(Title)
(Company)
(Address)
(Postal code)
Subject: Inventory of hazardous materials
Dear Sir or Madam,
The City of ABC actively participates in the work of the JCC (Joint Coordinating Committee for
managing the risks of major industrial accidents).
As its mandate, this committee strives to ensure that the risks of industrial accidents related to
the presence of hazardous materials on the site of companies within our territory are made very
clear. Next, the objective is to implement measures for preventing accidents, developing emer-
gency response plans in situations where accidents could occur, informing the public of the risks
and the measures put in place for controlling the consequences, and assuring the safety of cit-
izens.
The first step of our process, which we are inviting you to participate in today, consists of send-
ing an inventory form for hazardous materials to the companies within the covered territory.
Your role in this exercise consists of indicating, on the list of hazardous materials, the quantity
of substances that you hold in amounts exceeding threshold quantity. We would appreciate
your cooperation and ask you to kindly return the completed form before (day – month – year).
To help you respond to this request, you will find enclosed a guide that introduces the JCC and
explains the entire process. A representative from the Fire Protection Service, Mr./Mrs. XY, who
you may reach at 000-0000, will contact you soon to offer assistance, if needed.
Respectfully yours,
Chief Executive Officer,
YZ
Encl.

Annex 1
Brief Instructions
Inventory of Hazardous Materials
1. Identification
To facilitate the identification of your products, we recommend that you use the WHMIS
(Workplace Hazardous Materials Information System) identification sheets, which you should
already have in your possession.
In the “Product Identification” section of the identification sheets, you will give the exact name
of the product as well as the other names used (synonyms).
In the section entitled “Ingredients and Toxicological Properties,” you will give the composition
of the product. If it is a solution or a mixture, this section will identify all the products that are
part of the composition, as well as the percentage of the total volume.
2. Pure substances and mixtures

The products included on the list are pure products. It is possible that one of these products is
found in a solution or a mixture bearing another name.
You must include all the mixed products whose mixtures contain at least 1% of a substance
appearing on the list. In the case of substances that are classified as toxic, you must calculate
the actual weight of the substance present in the mixture and use that weight to determine
whether a threshold quantity is present. This same rule generally applies to substances that are
classified as flammable. However, when exceptions occur, we will refer you to the guide for
more details.
3. Quantities
The quantities requested on the list provided are in kilograms. To help you evaluate the quanti-
ties, remember that one litre of liquid weighs roughly one kilogram.

Origin of Hazardous
Materials
2
Annex
111
Annex 2
H azardous materials are a group of products (substances) that, due to their chemical and
physical properties, require particular safety measures for their management (manufacturing,
use, storage, transport, disposal). A substance is a material that is characterized by its proper-
ties. Toxic, infectious, flammable, explosive, oxidizing, corrosive and radioactive substances are
all hazardous materials. It follows that the greater the quantity and diversity of these products
in the same area, the greater the risks related to their management.
Elements that Make up this List:

• List 1 of priority hazardous substances, according to the Major Industrial Accidents Council of
Canada (MIACC) (Lists of Hazardous Substances, 1994).
• List of Regulated Toxic and Flammable Substances and Thresholds for Accidental Release
Prevention, Environmental Protection Agency (EPA) (Federal Register, vol. 59, no. 20, 19
January 1993, pp. 4493-4499).
• Hazardous materials included in Lists 2 and 3 of MIACC (Lists of Hazardous Substances, 1994),
when these are also included in the EPA list, in the list of substances regulated by the
Occupational Safety and Health Administration (OSHA) (Federal Register, vol. 57, no. 36, 24
February 1992) or in the list of substances listed by the National Fire Protection Agency (NFPA)
in NFPA 325 (Guide to Fire Hazard Properties of Flammable Liquids, Gases, and Volatile Solids,
5 August 1994) as representing an extreme danger (level 4) from the point of view of health,
flammability or reactivity.
• Threshold quantities are those regulated by the EPA, or by default those regulated by OSHA,
or by default those recommended by List 2 of MIACC. The identification numbers are those
of the United Nations (UN) and those of the Chemical Abstracts Service (CAS).
If an industry has a substance that is not mentioned in the List of Hazardous Materials of CRAIM,
but for which the properties, conditions and storage create a risk of a major industrial accident,
this substance should be reported to the JCC.
The List of Hazardous Materials of CRAIM is presented in Annex 3 under four (4) dif-
ferent orders:
• by order of CRAIM class;
• by alphabetical order of English name;
• by order of CAS number; and
• by order of United Nations (UN) number.

Annex 2
Picture 1
Development of the list of CRAIM
List Seveso 1 EPA Extremely

Origin of List 1 Hazardous
List of accidents Substances
involving hazardous
substances 1990
Domestic
Substances OSHA EPA RMP
List 1910.119 list Threshold set
by analysis
Yes
MIACC List 1 MIACC List 2 (Safety)

Threshold set by MIACC List 3 (Environment)
expert opinion Thresholds by expert opinion
NFPA
235 OSHA
H4, F4, R4 1910-119
CRAIM List:
• 63 FLammables (RMP)
• 77 Toxics (RMP)
• 10 Flammables (MIACC-OSHA
or NFPA)
• 20 Toxiques (MIACC-OSHA or
NFPA 325)
• 4 Explosives
H4 : Health class 4
• 1 Miscellaneous
F4 : Fire class 4
R4 : Reactivity Class 4 Total: 175 substances

Annex 2
Methodology for setting threshold quantities for

toxic substances
The methodology followed by EPA for selecting the substances of the RMP list is essentially
based on concerns for the protection of persons which could be exposed to airborne toxic con-
centrations of hazardous substances or the effects of explosions.
Here are the rules followed by EPA

Rule 1: The substance must be in commerce in the United States and have a CAS (Chemical
Abstract System) number.
Rule 2: It must be a pure substances, there are four exceptions (fluorhydric acid with concen-
tration 50% or greater, hydrochloric acid with concentration 37% or greater, nitric acid
with concentration 80% or greate, and ammonia with concentration 20% or greater.
Toxic substances
Rule 3: Toxicity
(a) Inhalation LC50 = 0,5 milligrams per litre of air (for exposure = 4 hours, or
(b) Dermal LD50 = 25 milligrammes per kilogramme of body weight of exposed animal.
Where LC50 is the median concentration in air at which 50 percent of the test animals died, and
LD50 is the median lethal dose that killed 50 percent of the test animals. In the absence of LC50
or LD50 data, LCLo or LDLo data were used for listing, where LCLo is the lethal concentration low,
or lowest concentration in air at which any of the test animals died.
Rule 4: A vapour pressure1 of 10 millimetres of mercury (mm Hg) was used as a baseline. Toxic
gases and liquid with a vapour pressure of 10 mm Hg or higher under ambient condi-
tions were considered for listing.
Rule 5: The threshold quantities are set between 500 lbs and 20 000 lbs based on a matrix tak-
ing into account the ratio toxicity divided by volatility, in accordance with the following
equation :
Index = T
V
T = Toxicity: Immediately Dangerous for Life and Health concentrations version 1990
(IDLH1990)
V = 1.6 x MW 0.67
T + 273
Where:
MW = is the molecular weight of the substance, and,
T = T is the Boiling point in degrees Celsius.
1
Vapour pressure : Physical property of a liquid describing its capacity to vaporise. If this liquid is placed in a closed and
evacuated container, it will partly vaporise to develop a pressure as a fonction of its temperature.

Annex 2
Table 1
Index and threshold quantities
Index Threshold Quantities

Metric tonnes (lbs)
<0,01 0,22* (500)

0,01 ≤Index<0,05 0,45*(1 000)
0,05≤Index<0,1 1,13* (2 500)
0,1≤Index<0,3 2,27* (5 000)
0,3≤Index<1 4,50* (10 000)
1≤ Index<10 6,80* (15 000)
≥10 9,10* i(20 000)
*Rounded to two decimals
Flammables substances
Flammable gases and liquids are included in the list based on their flash point and their boiling
points in accordance with the criteria used by the National Fire Protection Association (NFPA) for
the highest risk level i.e. 73°F (22.8°C) and a boiling point less than 100°F (37.8°C)2. Only sub-
stances in commercial production are included.
The threshold quantity for flammable substances was set at 4,54 tonnes (10 000 lbs). This dor-
responds to an overpressure of 3 pounds per square inch at 100 metres in case of the explosion
of an explosive vapour cloud.
Some flammable substances that are also toxic, are subjected to the process for toxic sustances
and the lowest threshold between 4,54 tonnes (10 000 lbs) and the threshold quantity for a
toxic substance with the calculated index is retained.
Substances of CRAIM
The CRAIM toxic substances were analysed using the EPA Classification process and results are
shown in Table 2.
The CRAIM flammable substances were anlysed taking into account their vapour pressure and
their potential to create an overpressure of 3 pounds per square inch at 100 metres in case of
the explosion of an explosive vapour cloud.
2
NFPA, Fire Protection Guide on Hazardous Material, 1984 , 8th Edition, Quicy MA

List of Hazardous Materials
3
Annex
117
Annex 3
Introduction
T o make its use easier, the List of Hazardous Materials is now displayed under four (4) dif-
ferent formats to allow the companies to more readily determine if a hazardous material is
included within the list.
The formats are as following:

• by order of CRAIM class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .page 121
• by alphabetical order of English name . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .page 129
• by order of CAS number . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .page 137
• by order of United Nations (UN) number . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .page 145

Annex 3
List of Hazardous
Materials of CRAIM
by order of CRAIM class

Annex 3
LIST OF HAZARDOUS MATERIALS OF CRAIM

(by order of CRAIM class)
Name of substances Threshold
CRAIM
quantity
English name French name (tonne) CAS No. UN No. Class Origin Remarks
Listed flammable substance (EPA)

1,1-difluoroethylene difluoro-1,1 éthylène 4.5 75-38-7 1959 A EPA
(vinylidene fluoride)
1,3-butadiene butadiène-1,3 4.5 106-99-0 1010 A EPA
1,3-pentadiene pentadiène-1,3 4.5 504-60-9 no number A EPA
1-buten-3-yne (vinyl acetylene) acétylène de vinyle (butényne) 4.5 689-97-4 no number A EPA
1-butene butène-1 (butylène) 4.5 106-98-9 1012 A EPA
1-chloropropene chloro-1 propène 4.5 590-21-6 no number A EPA
(1-chloropropylene)
1-pentene pentène-1 4.5 109-67-1 1108 A EPA
2,2-dimethylpropane diméthyl-2,2 propane 4.5 463-82-1 2044 A EPA
2-butene butène-2 4.5 107-01-7 1055 A EPA
2-chloropropane chloro-2 propane 4.5 75-29-6 2356 A EPA
(isopropyl chloride)
2-chloropropene chloro-2 propène 4.5 557-98-2 2456 A EPA
(2-chloropropylene)
2-methyl-1-butene méthyl-2 butène-1 4.5 563-46-2 2459 A EPA
acetaldehyde acétaldéhyde 4.5 75-07-0 1089 A EPA
acetylene acétylène 4.5 74-86-2 1001 A EPA
bromotrifluoroethylene bromotrifluoréthylène 4.5 598-73-2 2419 A EPA
butane butane 4.5 106-97-8 1011 A EPA
butylene (butene) butylène (butène) 4.5 25167-67-3 1012 A EPA
carbonyl sulphide sulfure de carbonyle 4.5 463-58-1 2204 A EPA
(carbon oxysulphide)
chlorine monoxide oxyde de dichlore 4.5 7791-21-1 no number A EPA
(dichlorine oxide)
cis-2-butene (2-butene-cis) butène-2 cis 4.5 590-18-1 1055 A EPA
cis-2-pentene (beta-cis-amylene) pentène-2 cis 4.5 627-20-3 no number A EPA
cyanogen cyanogène 4.5 460-19-5 1026 A EPA
cyclopropane cyclopropane 4.5 75-19-4 1027 A EPA
dichlorosilane dichlorosilane 4.5 4109-96-0 2189 A EPA
difluoroethane difluoréthane 4.5 75-37-6 1030 A EPA
(1,1-difluoroethane) (difluoro-1,1 éthane)
dimethyl ether (methyl ether) éther méthylique 4.5 115-10-6 1033 A EPA
(oxyde de diméthyle)
dimethylamine diméthylamine 4.5 124-40-3 1032 & 1160 A EPA
ethane éthane 4.5 74-84-0 1035 & 1961 A EPA
ethyl chloride chlorure d’éthyle 4.5 75-00-3 1037 A EPA
ethyl ether (diethyl ether) éther éthylique (éther diéthylique) 4.5 60-29-7 1155 A EPA
ethyl mercaptan mercaptan éthylique 4.5 75-08-1 2363 A EPA
ethyl nitrite nitrite d’éthyle 4.5 109-95-5 1194 A EPA
ethylacetylene éthylacétylène 4.5 107-00-6 2452 A EPA
A = Listed flammable substance (EPA) B = Listed toxic substance (EPA) C = Listed flammable substance (CRAIM)
D = Listed toxic substance (CRAIM) E = Listed explosive substance (CRAIM) F = Listed miscellaneous substance (CRAIM)

Annex 3

CRAIM
quantity
English name French name ( tonne) CAS No. UN No. Class Origin Remarks
ethylamine éthylamine 4.5 75-04-7 1036 & 2270 A EPA
ethylene éthylène 4.5 74-85-1 1038 & 1962 A EPA
hydrogen hydrogène 4.5 1333-74-0 1049 A EPA
isobutane isobutane 4.5 75-28-5 1969 A EPA
isobutylene (2-methylpropene) isobutylène 4.5 115-11-7 1055 A EPA
isopentane (2-methylbutane) isopentane 4.5 78-78-4 1265 A EPA
isoprene isoprène 4.5 78-79-5 1218 A EPA
isopropylamine isopropylamine 4.5 75-31-0 1221 A EPA
methane méthane 4.5 74-82-8 1971 & 1972 A EPA
methyl formate formiate de méthyle 4.5 107-31-3 1243 A EPA
methylacetylene (propyne) méthylacétylène 4.5 74-99-7 1060 A EPA
methylamine méthylamine 4.5 74-89-5 1061 A EPA
n-pentane (pentane) n-pentane (pentane) 4.5 109-66-0 1265 A EPA
propadiene propadiène 4.5 463-49-0 2200 A EPA
propane propane 4.5 74-98-6 1978 A EPA
propylene propylène 4.5 115-07-1 1077 A EPA
silane silane 4.5 7803-62-5 2203 A EPA
tetrafluoroethylene tétrafluoréthylène 4.5 116-14-3 1081 A EPA
tetramethylsilane tétraméthylsilane 4.5 75-76-3 2749 A EPA
trans-2-butene (2-butene-trans) butène-2 trans 4.5 624-64-6 1055 A EPA
trans-2-pentene pentène-2 trans 4.5 646-04-8 no number A EPA
(trans-beta-amylene)
trichlorosilane trichlorosilane 4.5 10025-78-2 1295 A EPA
trifluorochloroethylene trifluorochloréthylène 4.5 79-38-9 1082 A EPA
(chlorotrifluoroethylene)
trimethylamine triméthylamine 4.5 75-50-3 1083 & 1297 A EPA
vinyl chloride chlorure de vinyle 4.5 75-01-4 1086 A EPA
vinyl ethyl ether (ethyl vinyl ether) éther éthylvinylique 4.5 109-92-2 1302 A EPA
vinyl fluoride fluorure de vinyle 4.5 75-02-5 1860 A EPA
vinyl methyl ether éther méthylvinylique 4.5 107-25-5 1087 A EPA
vinylidene chloride chlorure de vinylidène 4.5 75-35-4 1303 A EPA
Listed toxic substance (EPA)
1,1-dimethylhydrazine diméthyl-1,1 hydrazine 6.8 57-14-7 1163 B EPA
acrolein acroléine 2.27 107-02-8 1092 B EPA
acrylonitrile acrylonitrile 9.1 107-13-1 1093 B EPA
acryloyl chloride (acrylyl chloride) chlorure d’acryloyle 2.27 814-68-6 no number B EPA
allyl alcohol alcool allylique 6.8 107-18-6 1098 B EPA
allylamine allylamine 4.5 107-11-9 2334 B EPA
ammonia, anhydrous ammoniac 4.5 7664-41-7 1005 B EPA
ammonia solution ammoniaque solution 9.1 7664-41-7 2073 & 2672 B EPA
(concentration 20% or greater) (concentration 20% ou plus)

Annex 3

CRAIM
quantity
arsenic trichloride trichlorure d’arsenic 6.8 7784-34-1 1560 B EPA
(arsenous trichloride) (chlorure d’arsenic)
arsine arsine 0.45 7784-42-1 2188 B EPA
bis(chloromethyl) ether éther dichlorodiméthylique 0.45 542-88-1 2249 B EPA
(dichlorodimethyl ether)
boron trichloride trichlorure de bore 2.27 10294-34-5 1741 B EPA
boron trifluoride trifluorure de bore 2.25 7637-07-2 1008 B EPA
boron trifluoride éthérate diméthylique 6.8 353-42-4 2965 B EPA
dimethyl etherate de trifluorure de bore
bromine brome 4.5 7726-95-6 1744 B EPA
carbon disulphide disulfure de carbone 9.1 75-15-0 1131 B EPA
chlorine chlore 1.13 7782-50-5 1017 B EPA
chlorine dioxide dioxyde de chlore 0.45 10049-04-4 no number B EPA
chloroform (trichloromethane) chloroforme (trichlorométhane) 9.1 67-66-3 1888 B EPA
chloromethyl methyl ether éther méthylique monochloré 2.27 107-30-2 1239 B EPA
(methyl chloromethyl ether)
crotonaldehyde crotonaldéhyde 9.1 4170-30-3 1143 B EPA
cyanogen chloride chlorure de cyanogène 4.5 506-77-4 1589 B EPA
cyclohexylamine cyclohexylamine 6.8 108-91-8 2357 B EPA
diborane diborane 1.13 19287-45-7 1911 B EPA
dimethyldichlorosilane diméthyldichlorosilane 2.27 75-78-5 1162 B EPA
(dichlorodimethylsilane)
epichlorohydrin épichlorhydrine 9.1 106-89-8 2023 B EPA
ethylene oxide oxyde d'éthylène 4.5 75-21-8 1040 B EPA
ethylenediamine éthylènediamine 9.1 107-15-3 1604 B EPA
ethyleneimine éthylèneimine 4.5 151-56-4 1185 B EPA
fluorine fluor 0.45 7782-41-4 1045 B EPA
formaldehyde, solution formaldéhyde en solution 6.8 50-00-0 1198 & 2209 B EPA
furan furanne 2.27 110-00-9 2389 B EPA
hydrazine hydrazine 6.8 302-01-2 2029 B EPA
hydrochloric acid acide chlorhydrique 6.8 7647-01-0 1789 B EPA
hydrofluoric acid acide fluorhydrique 0.45 7664-39-3 1790 B EPA
hydrogen chloride, anhydrous chlorure d’hydrogène 2.27 7647-01-0 2186 & 1050 B EPA
hydrogen cyanide cyanure d’hydrogène 1.13 74-90-8 1051 & 1613 B EPA
(hydrocyanic acid) (acide cyanhydrique) & 1614
hydrogen selenide séléniure d’hydrogène 0.22 7783-07-5 2202 B EPA
hydrogen sulphide sulfure d’hydrogène 4.5 7783-06-4 1053 B EPA
iron pentacarbonyl fer pentacarbonyle 1.13 13463-40-6 1994 B EPA
isobutyronitrile isobutyronitrile 9.1 78-82-0 2284 B EPA
isopropyl chloroformate chloroformiate d’isopropyle 6.8 108-23-6 2407 B EPA
methyl chloride chlorure de méthyle 4.5 74-87-3 1063 B EPA

Annex 3

CRAIM
quantity
methyl chloroformate chloroformiate de méthyle 2.27 79-22-1 1238 B EPA
methyl isocyanate isocyanate de méthyle 4.5 624-83-9 2480 B EPA
methyl mercaptan mercaptan méthylique 4.5 74-93-1 1064 B EPA
(méthylmercaptan)
methyl thiocyanate thiocyanate de méthyle 9.1 556-64-9 no number B EPA
methylacrylonitrile méthacrylonitrile 4.5 126-98-7 3079 B EPA
methylhydrazine méthylhydrazine 6.8 60-34-4 1244 B EPA
(monomethyl hydrazine)
methyltrichlorosilane méthyltrichlorosilane 2.27 75-79-6 1250 B EPA
(trichlorométhylsilane)
nickel carbonyl nickel-tétracarbonyle 0.45 13463-39-3 1259 B EPA
nitric acid acide nitrique 6.8 7697-37-2 2031 & 2032 B EPA
nitric oxide oxyde nitrique 4.5 10102-43-9 1660 B EPA
(monoxyde d’azote )
n-propyl chloroformate chloroformiate de n-propyle 6.8 109-61-5 2740 B EPA
(propyl chloroformate)
perchloromethyl mercaptan mercaptan méthylique perchloré 4.5 594-42-3 1670 B EPA
peroxyacetic acid (peracetic acid) acide peroxyacétique 4.5 79-21-0 2131 B EPA
phosgene phosgène 0.22 75-44-5 1076 B EPA
phosphine phosphine 2.27 7803-51-2 2199 B EPA
phosphorus oxychloride oxychlorure de phosphore 2.27 10025-87-3 1810 B EPA
phosphorus trichloride trichlorure de phosphore 6.8 7719-12-2 1809 B EPA
piperidine pipéridine 6.8 110-89-4 2401 B EPA
propionitrile propionitrile 4.5 107-12-0 2404 B EPA
propylene oxide oxyde de propylène 4.5 75-56-9 1280 B EPA
propyleneimine propylèneimine 4.5 75-55-8 1921 B EPA
sulphur dioxide dioxyde de soufre 2.27 7446-09-5 1079 B EPA
sulphur tetrafluoride tétrafluorure de soufre 1.13 7783-60-0 2418 B EPA
sulphur trioxide trioxyde de soufre 4.5 7446-11-9 1829 B EPA
sulphuric acid, fuming (oleum) acide sulfurique, fumant (oléum) 4.5 8014-95-7 1831 B EPA
tetramethyl lead plomb tétraméthyle 4.5 75-74-1 no number B EPA
tetranitromethane tétranitrométhane 4.5 509-14-8 1510 B EPA
titanium tetrachloride tétrachlorure de titane 1.13 7550-45-0 1838 B EPA
toluene diisocyanate diisocyanate de toluène 4.5 26471-62-5 2078 B EPA
toluene-2,4-diisocyanate toluène-2,4 diisocyanate 4.5 584-84-9 2078 B EPA
trans-crotonaldehyde crotonaldéhyde trans 9.1 123-73-9 1143 B EPA
trimethylchlorosilane triméthylchlorosilane 4.5 75-77-4 1298 B EPA
(chlorotrimethylsilane)
vinyl acetate acétate de vinyle 6.8 108-05-4 1301 B EPA

Annex 3

CRAIM
quantity
Listed flammable substance (CRAIM)

benzene benzène 10 71-43-2 1114 C MIACC List #1 flammable
cyclohexane cyclohexane 550 110-82-7 1145 C MIACC List #1 flammable
dimethyl sulphide sulfure de diméthyle 150 75-18-3 1164 C MIACC List #2 flammable
& NFPA (F=4)
ethylbenzene éthylbenzène 7000 100-41-4 1175 C MIACC List #1 flammable
gasoline (motor fuel) essence 150 86290-81-5 1203 C MIACC List #1 flammable
(carburants pour moteur d’automobile)
naphtha naphta 50 8030-30-6 1255 & 1256 C MIACC List #1 flammable
& 2553
natural gas gaz naturel liquéfié 4.5 8006-14-2 1972 C MIACC List #1 flammable
tert-butylamine butylamine tertiaire 150 75-64-9 1125 C MIACC List #2 flammable
(2-amino-2-methylpropane) (butylamine tert) & NFPA (F=4)
toluene toluène 2500 108-88-3 1294 C MIACC List #1 flammable
xylenes xylènes 8000 1330-20-7 1307 C MIACC List #1 flammable
Listed toxic substance (CRAIM)
1,2-dichloroethane dichlorure d’éthylène 6.8 107-06-2 1184 D MIACC List #1 toxic
(ethylene dichloride)
allyl chloride chlorure d'allyle 9.1 107-05-1 1100 D MIACC List #2 toxic
& OSHA & flammable
carbon monoxide monoxyde de carbone 6.8 630-08-0 1016 D MIACC List #2 toxic
& NFPA (F=4)
chloropicrin chloropicrine 2.27 76-06-2 1580 D MIACC List #2 toxic
(trichloronitromethane) (trichloronitrométhane) & OSHA
chlorosulphonic acid acide chlorosulfonique 2.27 7790-94-5 1754 D MIACC List #2 toxic
& NFPA (H=4) & decomposes
cyanogen bromide bromure de cyanogène 4.5 506-68-3 1889 D MIACC List #2 toxic
& NFPA (H=4)
ethylene chlorohydrin monochlorhydrine du glycol 4.5 107-07-3 1135 D MIACC List #2 toxic
(2-chloroethanol) (chloro-2 éthanol) & NFPA (H=3)
hydrogen bromide bromure d’hydrogène 1.13 10035-10-6 1048 & 1788 D MIACC List #2 toxic
(hydrobromic acid) (acide bromhydrique) & OSHA
hydrogen fluoride, anhydrous fluorure d’hydrogène 0.45 7664-39-3 1052 D EC toxic
ketene cétène 0.22 463-51-4 no number D MIACC List #2 toxic
& OSHA
mercury mercure 1 7439-97-6 2809 D MIACC List #1 toxic
methyl bromide bromure de méthyle 2.27 74-83-9 1062 D MIACC List #2 toxic
& OSHA
methyl iodide iodure de méthyle 4.5 74-88-4 2644 D MIACC List #1 toxic
nitrogen dioxide dioxyde d’azote 1.13 10102-44-0 1067 D MIACC List #2 toxic
& OSHA
osmium tetroxide tétroxyde d’osmium 0.22 20816-12-0 2471 D MIACC List #2 toxic
& OSHA & explosive
perchloryl fluoride fluorure de perchloryle 6.8 7616-94-6 3083 D MIACC List #2 toxic
(trioxychlorofluoride) (trioxychlorofluorure) & OSHA
phenol phénol 9.1 108-95-2 1671 & 2312 D MIACC List #2 toxic
& 2821 & NFPA (H=4) & poisonous

CRAIM
quantity
stibine stibine 2.27 7803-52-3 2676 D MIACC List #2 toxic
& OSHA & flammable
tetraethyl lead plomb tétraéthyle 2.27 78-00-2 1649 D MIACC List #1 toxic
& flammable
thionyl chloride chlorure de thionyle 6.8 7719-09-7 1836 D MIACC List #2 toxic
& OSHA & decomposes
Listed explosive substance (CRAIM)
ammonium perchlorate perchlorate d’ammonium 3.4 7790-98-9 1442 E MIACC List #2 oxidizing
& OSHA & explosive
explosives explosifs (classe 1.1) 2.25 E explosive
hydrogen peroxide peroxyde d’hydrogène 3.4 7722-84-1 2015 E MIACC List #2 oxidizing
(concentration 52% or greater) (concentration 52% ou plus) & OSHA & reactive (explosive)
sodium chlorate chlorate de sodium 10 7775-09-9 1495 E MIACC List #1 oxidizing if
confined in barrel
Listed miscellaneous substance (CRAIM)
phosphorus, white phosphore blanc 1 7723-14-0 2447 F MIACC List #2 flammable
& NFPA (F=4) & toxic combustion
product
128
Annex 3
List of Hazardous
Materials of CRAIM
by alphabetical order of English name

Annex 3

(by alphabetical order of English name)
CRAIM
quantity
1,1-difluoroethylene difluoro-1,1 éthylène 4.5 75-38-7 1959 A EPA
1,1-dimethylhydrazine diméthyl-1,1 hydrazine 6.8 57-14-7 1163 B EPA
1,2-dichloroethane dichlorure d'éthylène 6.8 107-06-2 1184 C MIACC List #1 flammable
1,3-butadiene butadiène-1,3 4.5 106-99-0 1010 A EPA
1,3-pentadiene pentadiène-1,3 4.5 504-60-9 no number A EPA
1-buten-3-yne (vinyl acetylene) acétylène de vinyle (butényne) 4.5 689-97-4 no number A EPA
1-butene butène-1 (butylène) 4.5 106-98-9 1012 A EPA
1-chloropropene chloro-1 propène 4.5 590-21-6 no number A EPA
(1-chloropropylene)
1-pentene pentène-1 4.5 109-67-1 1108 A EPA
2,2-dimethylpropane diméthyl-2,2 propane 4.5 463-82-1 2044 A EPA
2-butene butène-2 4.5 107-01-7 1055 A EPA
2-chloropropane chloro-2 propane 4.5 75-29-6 2356 A EPA
2-chloropropene chloro-2 propène 4.5 557-98-2 2456 A EPA
(2-chloropropylene)
acetaldehyde acétaldéhyde 4.5 75-07-0 1089 A EPA
acetylene acétylène 4.5 74-86-2 1001 A EPA
acrolein acroléine 2.27 107-02-8 1092 B EPA
acrylonitrile acrylonitrile 9.1 107-13-1 1093 B EPA
acryloyl chloride (acrylyl chloride) chlorure d’acryloyle 2.27 814-68-6 no number B EPA
allyl alcohol alcool allylique 6.8 107-18-6 1098 B EPA
allyl chloride chlorure d’allyle 9.1 107-05-1 1100 D MIACC List #2 toxic
& OSHA & flammable
allylamine allylamine 4.5 107-11-9 2334 B EPA
ammonia, anhydrous ammoniac 4.5 7664-41-7 1005 B EPA
ammonia solution ammoniaque solution 9.1 7664-41-7 2073 & 2672 B EPA
ammonium perchlorate perchlorate d’ammonium 3.4 7790-98-9 1442 E MIACC List #2 oxidising
& OSHA & explosive
arsenic trichloride trichlorure d’arsenic 6.8 7784-34-1 1560 B EPA
arsine arsine 0.45 7784-42-1 2188 B EPA
benzene benzène 10 71-43-2 1114 C MIACC List #1 flammable
bis(chloromethyl) ether éther dichlorodiméthylique 0.45 542-88-1 2249 B EPA
boron trichloride trichlorure de bore 2.27 10294-34-5 1741 B EPA
boron trifluoride trifluorure de bore 2.27 7637-07-2 1008 B EPA
boron trifluoride éthérate diméthylique 6.8 353-42-4 2965 B EPA
bromine brome 4.5 7726-95-6 1744 B EPA

Annex 3

CRAIM
quantity
bromotrifluoroethylene bromotrifluoréthylène 4.5 598-73-2 2419 A EPA
butane butane 4.5 106-97-8 1011 A EPA
butylene (butene) butylène (butène) 4.5 25167-67-3 1012 A EPA
carbon disulphide disulfure de carbone 9.1 75-15-0 1131 B EPA
carbon monoxide monoxyde de carbone 6.8 630-08-0 1016 D MIACC List #2 toxic
& NFPA (F=4)
carbonyl sulphide sulfure de carbonyle 4.5 463-58-1 2204 A EPA
(carbon oxysulfide)
chlorine chlore 1.13 7782-50-5 1017 B EPA
chlorine dioxide dioxyde de chlore 0.45 10049-04-4 no number B EPA
chlorine monoxide oxyde de dichlore 4.5 7791-21-1 no number A EPA
(dichlorine oxide)
chloroform (trichloromethane) chloroforme (trichlorométhane) 9.1 67-66-3 1888 B EPA
chloromethyl methyl ether éther méthylique monochloré 2.27 107-30-2 1239 B EPA
chloropicrin chloropicrine 2.27 76-06-2 1580 D MIACC List #2 toxic
chlorosulphonic acid acide chlorosulfonique 2.27 7790-94-5 1754 D MIACC List #2 toxic
cis-2-butene (2-butene-cis) butène-2 cis 4.5 590-18-1 1055 A EPA
cis-2-pentene (beta-cis-amylene) pentène-2 cis 4.5 627-20-3 no number A EPA
crotonaldehyde crotonaldéhyde 9.1 4170-30-3 1143 B EPA
cyanogen cyanogène 4.5 460-19-5 1026 A EPA
cyanogen bromide bromure de cyanogène 4.5 506-68-3 1889 D MIACC List #2 toxic
& NFPA (H=4)
cyanogen chloride chlorure de cyanogène 4.5 506-77-4 1589 B EPA
cyclohexane cyclohexane 550 110-82-7 1145 C MIACC List #1 flammable
cyclohexylamine cyclohexylamine 6.8 108-91-8 2357 B EPA
cyclopropane cyclopropane 4.5 75-19-4 1027 A EPA
diborane diborane 1.13 19287-45-7 1911 B EPA
dichlorosilane dichlorosilane 4.5 4109-96-0 2189 A EPA
difluoroethane difluoréthane 4.5 75-37-6 1030 A EPA
dimethyl ether (methyl ether) éther méthylique 4.5 115-10-6 1033 A EPA
dimethyl sulphide sulfure de diméthyle 150 75-18-3 1164 C MIACC List #2 flammable
& NFPA (F=4)
dimethylamine diméthylamine 4.5 124-40-3 1032 & 1160 A EPA
dimethyldichlorosilane diméthyldichlorosilane 2.27 75-78-5 1162 B EPA
epichlorohydrin épichlorhydrine 9.1 106-89-8 2023 B EPA
ethane éthane 4.5 74-84-0 1035 & 1961 A EPA
ethyl chloride chlorure d’éthyle 4.5 75-00-3 1037 A EPA
ethyl ether (diethyl ether) éther éthylique 4.5 60-29-7 1155 A EPA
(éther diéthylique)

Annex 3

CRAIM
quantity
English name French name (tonne) CAS No. UN/NIP No. Class Origin Remarks
ethyl mercaptan mercaptan éthylique 4.5 75-08-1 2363 A EPA
ethyl nitrite nitrite d’éthyle 4.5 109-95-5 1194 A EPA
ethylacetylene éthylacétylène 4.5 107-00-6 2452 A EPA
ethylamine éthylamine 4.5 75-04-7 1036 & 2270 A EPA
ethylbenzene éthylbenzène 7000 100-41-4 1175 C MIACC List #1 flammable
ethylene éthylène 4.5 74-85-1 1038 & 1962 A EPA
ethylene chlorohydrin monochlorhydrine du glycol 4.5 107-07-3 1135 D MIACC List #2 toxic
ethylene oxide oxyde d’éthylène 4.5 75-21-8 1040 B EPA
ethylenediamine éthylènediamine 9.1 107-15-3 1604 B EPA
ethyleneimine éthylèneimine 4.5 151-56-4 1185 B EPA
fluorine fluor 0.45 7782-41-4 1045 B EPA
formaldehyde, solution formaldéhyde en solution 6.8 50-00-0 1198 & 2209 B EPA
furan furanne 2.27 110-00-9 2389 B EPA
gasoline (motor fuel) essence 150 86290-81-5 1203 C MIACC List #1 flammable
hydrazine hydrazine 6.8 302-01-2 2029 B EPA
hydrochloric acid acide chlorhydrique 6.8 7647-01-0 1789 B EPA
hydrofluoric acid acide fluorhydrique 0.45 7664-39-3 1790 B EPA
hydrogen hydrogène 4.5 1333-74-0 1049 A EPA
hydrogen bromide bromure d’hydrogène 1.13 10035-10-6 1048 & 1788 D MIACC List #2 toxic
hydrogen chloride, anhydrous chlorure d’hydrogène 2.25 7647-01-0 2186 & 1050 B EPA
hydrogen cyanide cyanure d’hydrogène 1.13 74-90-8 1051 & 1613 B EPA
hydrogen fluoride, anhydrous fluorure d’hydrogène 0.45 7664-39-3 1052 D EC
hydrogen peroxide peroxyde d’hydrogène 3.4 7722-84-1 2015 E MIACC List #2 oxidising
(concentration 52% or greater) (concentration 52% ou plus) & OSHA & reactive (explosive)
hydrogen selenide séléniure d’hydrogène 0.22 7783-07-5 2202 B EPA
hydrogen sulphide sulfure d’hydrogène 4.5 7783-06-4 1053 B EPA
iron pentacarbonyl fer pentacarbonyle 1.13 13463-40-6 1994 B EPA
isobutane isobutane 4.5 75-28-5 1969 A EPA
isobutylene (2-methylpropene) isobutylène 4.5 115-11-7 1055 A EPA
isobutyronitrile isobutyronitrile 9.1 78-82-0 2284 B EPA
isopentane (2-methylbutane) isopentane 4.5 78-78-4 1265 A EPA
isoprene isoprène 4.5 78-79-5 1218 A EPA
isopropyl chloroformate chloroformiate d’isopropyle 6.8 108-23-6 2407 B EPA
isopropylamine isopropylamine 4.5 75-31-0 1221 A EPA
ketene cétène 0.22 463-51-4 no number D MIACC List #2 toxic
& OSHA
mercury mercure 1 7439-97-6 2809 D MIACC List #1 toxic

Annex 3

CRAIM
quantity
methane méthan 4.5 74-82-8 1971 & 1972 A EPA
methyl bromide bromure de méthyle 2.27 74-83-9 1062 D MIACC List #2 toxic
& OSHA
methyl chloride chlorure de méthyle 4.5 74-87-3 1063 B EPA
methyl chloroformate chloroformiate de méthyle 2.27 79-22-1 1238 B EPA
methyl formate formiate de méthyle 4.5 107-31-3 1243 A EPA
methyl iodide iodure de méthyle 4.5 74-88-4 2644 D MIACC List #1 toxic
methyl isocyanate isocyanate de méthyle 4.5 624-83-9 2480 B EPA
methyl mercaptan mercaptan méthylique 4.5 74-93-1 1064 B EPA
(méthylmercaptan)
methyl thiocyanate thiocyanate de méthyle 9.1 556-64-9 no number B EPA
methylacetylene (propyne) méthylacétylène 4.5 74-99-7 1060 A EPA
methylacrylonitrile méthacrylonitrile 4.5 126-98-7 3079 B EPA
methylamine méthylamine 4.5 74-89-5 1061 A EPA
methylhydrazine méthylhydrazine 6.8 60-34-4 1244 B EPA
methyltrichlorosilane méthyltrichlorosilane 2.27 75-79-6 1250 B EPA
naphtha naphta 50 8030-30-6 1255 & 1256 C MIACC List #1 flammable
& 2553
natural gas gaz naturel liquéfié 4.5 8006-14-2 1972 C MIACC List #1 flammable
nickel carbonyl nickel-tétracarbonyle 0.45 13463-39-3 1259 B EPA
nitric acid acide nitrique 6.8 7697-37-2 2031 & 2032 B EPA
nitric oxide oxyde nitrique 4.5 10102-43-9 1660 B EPA
(monoxyde d'azote )
nitrogen dioxide dioxyde d'azote 1.13 10102-44-0 1067 D MIACC List #2 toxic
& OSHA
n-pentane (pentane) n-pentane (pentane) 4.5 109-66-0 1265 A EPA
n-propyl chloroformate chloroformiate de n-propyle 6.8 109-61-5 2740 B EPA
osmium tetroxide tétroxyde d'osmium 0.22 20816-12-0 2471 D MIACC List #2 toxic
& OSHA & explosive
perchloromethyl mercaptan mercaptan méthylique perchloré 4.5 594-42-3 1670 B EPA
perchloryl fluoride fluorure de perchloryle 6.8 7616-94-6 3083 D MIACC List #2 toxic
(trioxychlorofluoride) (trioxychlorofluorure) & OSHA
peroxyacetic acid (Peracetic acid) acide peroxyacétique 4.5 79-21-0 2131 B EPA
phenol phénol 9.1 108-95-2 1671 & 2312 D MIACC List #2 toxic
& 2821 & NFPA (H=4) & poisonous
phosgene phosgène 0.22 75-44-5 1076 B EPA
phosphine phosphine 2.27 7803-51-2 2199 B EPA
phosphorus oxychloride oxychlorure de phosphore 2.27 10025-87-3 1810 B EPA
phosphorus trichloride trichlorure de phosphore 6.8 7719-12-2 1809 B EPA
phosphorus, white phosphore blanc 1 7723-14-0 2447 F MIACC List #2 flammable
product

Annex 3

CRAIM
quantity
piperidine pipéridine 6.8 110-89-4 2401 B EPA
propadiene propadiène 4.5 463-49-0 2200 A EPA
propane propane 4.5 74-98-6 1978 A EPA
propionitrile propionitrile 4.5 107-12-0 2404 B EPA
propylene propylène 4.5 115-07-1 1077 A EPA
propylene oxide oxyde de propylène 4.5 75-56-9 1280 B EPA
propyleneimine propylèneimine 4.5 75-55-8 1921 B EPA
silane silane 4.5 7803-62-5 2203 A EPA
sodium chlorate chlorate de sodium 10 7775-09-9 1495 E MIACC List #1 oxidising & explosive
if confined in barrel
stibine stibine 2.27 7803-52-3 2676 D MIACC List #2 toxic
& OSHA & flammable
sulphur dioxide dioxyde de soufre 2.27 7446-09-5 1079 B EPA
sulphur tetrafluoride tétrafluorure de soufre 1.13 7783-60-0 2418 B EPA
sulphur trioxide trioxyde de soufre 4.5 7446-11-9 1829 B EPA
sulphuric acid, fuming (oleum) acide sulfurique, fumant (oléum) 4.5 8014-95-7 1831 B EPA
tert-butylamine butylamine tertiaire 150 75-64-9 1125 C MIACC List #2 flammable
tetraethyl lead plomb tétraéthyle 2.27 78-00-2 1649 D MIACC List #1 toxic
& flammable
tetrafluoroethylene tétrafluoréthylène 4.5 116-14-3 1081 A EPA
tetramethyl lead plomb tétraméthyle 2.27 75-74-1 no number B EPA
tetramethylsilane tétraméthylsilane 4.5 75-76-3 2749 A EPA
tetranitromethane tétranitrométhane 4.5 509-14-8 1510 B EPA
thionyl chloride chlorure de thionyle 6.8 7719-09-7 1836 D MIACC List #2 toxic
& OSHA & decomposes
titanium tetrachloride tétrachlorure de titane 1.13 7550-45-0 1838 B EPA
toluene toluène 2500 108-88-3 1294 C MIACC List #1 flammable
toluene diisocyanate diisocyanate de toluène 4.5 26471-62-5 2078 B EPA
trans-2-butene (2-butene-trans) butène-2 trans 4.5 624-64-6 1055 A EPA
trans-2-pentene pentène-2 trans 4.5 646-04-8 no number A EPA
trans-crotonaldehyde crotonaldéhyde trans 9.1 123-73-9 1143 B EPA
trichlorosilane trichlorosilane 4.5 10025-78-2 1295 A EPA
trifluorochloroethylene trifluorochloréthylène 4.5 79-38-9 1082 A EPA
trimethylamine triméthylamine 4.5 75-50-3 1083 & 1297 A EPA
trimethylchlorosilane triméthylchlorosilane 4.5 75-77-4 1298 B EPA
vinyl acetate acétate de vinyle 6.8 108-05-4 1301 B EPA
vinyl chloride chlorure de vinyle 4.5 75-01-4 1086 A EPA

Annex 3

CRAIM
quantity
vinyl ethyl ether éther éthylvinylique 4.5 109-92-2 1302 A EPA
(ethyl vinyl ether)
vinyl fluoride fluorure de vinyle 4.5 75-02-5 1860 A EPA
vinyl methyl ether éther méthylvinylique 4.5 107-25-5 1087 A EPA
vinylidene chloride chlorure de vinylidène 4.5 75-35-4 1303 A EPA
xylenes xylènes 8000 1330-20-7 1307 C MIACC List #1 flammable

Annex 3
List of Hazardous
Materials of CRAIM
by order of CAS number

Annex 3

(by order of CAS number)
CRAIM
quantity
CAS No. English name French name (tonne) UN No. Class Origin Remarks
50-00-0 formaldehyde, solution formaldéhyde en solution 6.8 1198 & 2209 B EPA
57-14-7 1,1-dimethylhydrazine diméthyl-1,1 hydrazine 6.8 1163 B EPA
60-29-7 ethyl ether (diethyl ether) éther éthylique (éther diéthylique) 4.5 1155 A EPA
60-34-4 methylhydrazine méthylhydrazine 6.8 1244 B EPA
67-66-3 chloroform (trichloromethane) chloroforme (trichlorométhane) 9.1 1888 B EPA
71-43-2 benzene benzène 10 1114 C MIACC List #1 flammable
74-82-8 methane méthane 4.5 1971 & 1972 A EPA
74-83-9 methyl bromide bromure de méthyle 2.27 1062 D MIACC List #2 toxic
& OSHA
74-84-0 ethane éthane 4.5 1035 & 1961 A EPA
74-85-1 ethylene éthylène 4.5 1038 & 1962 A EPA
74-86-2 acetylene acétylène 4.5 1001 A EPA
74-87-3 methyl chloride chlorure de méthyle 4.5 1063 B EPA
74-88-4 methyl iodide iodure de méthyle 4.5 2644 D MIACC List #1 toxic
74-89-5 methylamine méthylamine 4.5 1061 A EPA
74-90-8 hydrogen cyanide cyanure d’hydrogène 1.13 1051 & 1613 B EPA
74-93-1 methyl mercaptan mercaptan méthylique 4.5 1064 B EPA
(méthylmercaptan)
74-98-6 propane propane 4.5 1978 A EPA
74-99-7 methylacetylene (propyne) méthylacétylène 4.5 1060 A EPA
75-00-3 ethyl chloride chlorure d'éthyle 4.5 1037 A EPA
75-01-4 vinyl chloride chlorure de vinyle 4.5 1086 A EPA
75-02-5 vinyl fluoride fluorure de vinyle 4.5 1860 A EPA
75-04-7 ethylamine éthylamine 4.5 1036 & 2270 A EPA
75-07-0 acetaldehyde acétaldéhyde 4.5 1089 A EPA
75-08-1 ethyl mercaptan mercaptan éthylique 4.5 2363 A EPA
75-15-0 carbon disulphide disulfure de carbone 9.1 1131 B EPA
75-18-3 dimethyl sulphide sulfure de diméthyle 150 1164 C MIACC List #2 flammable
& NFPA (F=4)
75-19-4 cyclopropane cyclopropane 4.5 1027 A EPA
75-21-8 ethylene oxide oxyde d’éthylène 4.5 1040 B EPA
75-28-5 isobutane isobutane 4.5 1969 A EPA
75-29-6 2-chloropropane chloro-2 propane 4.5 2356 A EPA
75-31-0 isopropylamine isopropylamine 4.5 1221 A EPA
75-35-4 vinylidene chloride chlorure de vinylidène 4.5 1303 A EPA
75-37-6 difluoroethane difluoréthane 4.5 1030 A EPA
75-38-7 1,1-difluoroethylene difluoro-1,1 éthylène 4.5 1959 A EPA
75-44-5 phosgene phosgène 0.22 1076 B EPA
75-50-3 trimethylamine triméthylamine 4.5 1083 & 1297 A EPA

Annex 3

CRAIM
quantity
CAS No. English name French name (tonne) UN/NIP No. Class Origin Remarks
75-55-8 propyleneimine propylèneimine 4.5 1921 B EPA

75-56-9 propylene oxide oxyde de propylène 4.5 1280 B EPA
75-64-9 tert-butylamine butylamine tertiaire 150 1125 C MIACC List #2 flammable
75-74-1 tetramethyl lead plomb tétraméthyle 4.5 no number B EPA
75-76-3 tetramethylsilane tétraméthylsilane 4.5 2749 A EPA
75-77-4 trimethylchlorosilane triméthylchlorosilane 4.5 1298 B EPA
75-78-5 dimethyldichlorosilane diméthyldichlorosilane 2.27 1162 B EPA
75-79-6 methyltrichlorosilane méthyltrichlorosilane 2.27 1250 B EPA
76-06-2 chloropicrin chloropicrine 2.27 1580 D MIACC List #2 toxic
78-00-2 tetraethyl lead plomb tétraéthyle 2.27 1649 D MIACC List #1 toxic
& flammable
78-78-4 isopentane (2-methylbutane) isopentane 4.5 1265 A EPA
78-79-5 isoprene isoprène 4.5 1218 A EPA
78-82-0 isobutyronitrile isobutyronitrile 9.1 2284 B EPA
79-21-0 peroxyacetic acid (peracetic acid) acide peroxyacétique 4.5 2131 B EPA
79-22-1 methyl chloroformate chloroformiate de méthyle 2.27 1238 B EPA
79-38-9 trifluorochloroethylene trifluorochloréthylène 4.5 1082 A EPA
91-08-7 toluene-2,6-diisocyanate toluène-2,6 diisocyanate 4.5 2078 B EPA
100-41-4 ethylbenzene éthylbenzène 7000 1175 C MIACC List #1 flammable
106-89-8 epichlorohydrin épichlorhydrine 9.1 2023 B EPA
106-97-8 butane butane 4.5 1011 A EPA
106-98-9 1-butene butène-1 (butylène) 4.5 1012 A EPA
106-99-0 1,3-butadiene butadiène-1,3 4.5 1010 A EPA
107-00-6 ethylacetylene éthylacétylène 4.5 2452 A EPA
107-01-7 2-butene butène-2 4.5 1055 A EPA
107-02-8 acrolein acroléine 2.27 1092 B EPA
107-05-1 allyl chloride chlorure d’allyle 9.1 1100 D MIACC List #2 toxic
& OSHA & flammable
107-06-2 1,2-dichloroethane dichlorure d’éthylène 6.8 1184 D MIACC List #1 toxic
107-07-3 ethylene chlorohydrin monochlorhydrine du glycol 4.5 1135 D MIACC List #2 toxic
107-11-9 allylamine allylamine 4.5 2334 B EPA
107-12-0 propionitrile propionitrile 4.5 2404 B EPA
107-13-1 acrylonitrile acrylonitrile 9.1 1093 B EPA
107-15-3 ethylenediamine éthylènediamine 9.1 1604 B EPA
107-18-6 allyl alcohol alcool allylique 6.8 1098 B EPA
107-25-5 vinyl methyl ether éther méthylvinylique 4.5 1087 A EPA
D = Listed toxic substance (CRAIM) E = Listed explosive substance (CRAIM) F = Listed various substance (CRAIM)

Annex 3

CRAIM
quantity
107-30-2 chloromethyl methyl ether éther méthylique monochloré 2.27 1239 B EPA
107-31-3 methyl formate formiate de méthyle 4.5 1243 A EPA
108-05-4 vinyl acetate acétate de vinyle 6.8 1301 B EPA
108-23-6 isopropyl chloroformate chloroformiate d’isopropyle 6.8 2407 B EPA
108-88-3 toluene toluène 2500 1294 C MIACC List #1 flammable
108-91-8 cyclohexylamine cyclohexylamine 6.8 2357 B EPA
108-95-2 phenol phénol 9.1 1671 & 2312 D MIACC List #2 toxic & poisonous
& 2821 & NFPA (H=4)
109-61-5 n-propyl chloroformate chloroformiate de n-propyle 6.8 2740 B EPA
109-66-0 n-pentane (pentane) n-pentane (pentane) 4.5 1265 A EPA
109-67-1 1-pentene pentène-1 4.5 1108 A EPA
109-92-2 vinyl ethyl ether (ethyl vinyl ether) éther éthylvinylique 4.5 1302 A EPA
109-95-5 ethyl nitrite nitrite d’éthyle 4.5 1194 A EPA
110-00-9 furan furanne 2.27 2389 B EPA
110-82-7 cyclohexane cyclohexane 550 1145 C MIACC List #1 flammable
110-89-4 piperidine pipéridine 6.8 2401 B EPA
115-07-1 propylène propylene 4.5 1077 A EPA
115-10-6 dimethyl ether (methyl ether) éther méthylique 4.5 1033 A EPA
115-11-7 isobutylene (2-methylpropene) isobutylène 4.5 1055 A EPA
116-14-3 tetrafluoroethylene tétrafluoréthylène 4.5 1081 A EPA
123-73-9 trans-crotonaldehyde crotonaldéhyde trans 9.1 1143 B EPA
124-40-3 dimethylamine diméthylamine 4.5 1032 & 1160 A EPA
126-98-7 methylacrylonitrile méthacrylonitrile 4.5 3079 B EPA
151-56-4 ethyleneimine éthylèneimine 4.5 1185 B EPA
302-01-2 hydrazine hydrazine 6.8 2029 B EPA
353-42-4 boron trifluoride éthérate diméthylique 6.8 2965 B EPA
460-19-5 cyanogen cyanogène 4.5 1026 A EPA
463-49-0 propadiene propadiène 4.5 2200 A EPA
463-51-4 ketene cétène 0.22 no number D MIACC List #2 toxic
& OSHA
463-58-1 carbonyl sulphide sulfure de carbonyle 4.5 2204 A EPA
(carbon oxysulphide)
463-82-1 2,2-dimethylpropane diméthyl-2,2 propane 4.5 2044 A EPA
504-60-9 1,3-pentadiene pentadiène-1,3 4.5 no number A EPA
506-68-3 cyanogen bromide bromure de cyanogène 4.5 1889 D MIACC List #2 toxic
& NFPA (H=4)
506-77-4 cyanogen chloride chlorure de cyanogène 4.5 1589 B EPA
509-14-8 tetranitromethane tétranitrométhane 4.5 1510 B EPA
542-88-1 bis(chloromethyl) ether éther dichlorodiméthylique 0.45 2249 B EPA

Annex 3

CRAIM
quantity
556-64-9 methyl thiocyanate thiocyanate de méthyle 9.1 no number B EPA

557-98-2 2-chloropropene chloro-2 propène 4.5 2456 A EPA
(2-chloropropylene)
563-45-1 3-methyl-1-butene méthyl-3 butène-1 4.5 2561 A EPA
563-46-2 2-methyl-1-butene méthyl-2 butène-1 4.5 2459 A EPA
584-84-9 toluene-2,4-diisocyanate toluène-2,4 diisocyanate 4.5 2078 B EPA
590-18-1 cis-2-butene (2-butene-cis) butène-2 cis 4.5 1055 A EPA
590-21-6 1-chloropropene chloro-1 propène 4.5 no number A EPA
(1-chloropropylene)
594-42-3 perchloromethyl mercaptan mercaptan méthylique perchloré 4.5 1670 B EPA
598-73-2 bromotrifluoroethylene bromotrifluoréthylène 4.5 2419 A EPA
624-64-6 trans-2-butene (2-butene-trans) butène-2 trans 4.5 1055 A EPA
624-83-9 methyl isocyanate isocyanate de méthyle 4.5 2480 B EPA
627-20-3 cis-2-pentene (beta-cis-amylene) pentène-2 cis 4.5 no number A EPA
630-08-0 carbon monoxide monoxyde de carbone 6.8 1016 D MIACC List #2 toxic
& NFPA (F=4)
646-04-8 trans-2-pentene pentène-2 trans 4.5 no number A EPA
689-97-4 1-buten-3-yne (vinyl acetylene) acétylène de vinyle (butényne) 4.5 no number A EPA
814-68-6 acryloyl chloride (acrylyl chloride) chlorure d’acryloyle 2.27 no number B EPA
1330-20-7 xylenes xylènes 8000 1307 C MIACC List #1 flammable
1333-74-0 hydrogen hydrogène 4.5 1049 A EPA
4109-96-0 dichlorosilane dichlorosilane 4.5 2189 A EPA
4170-30-3 crotonaldehyde crotonaldéhyde 9.1 1143 B EPA
7439-97-6 mercury mercure 1 2809 D MIACC List #1 toxic
7446-09-5 sulphur dioxide dioxyde de soufre 2.27 1079 B EPA
7446-11-9 sulphur trioxide trioxyde de soufre 4.5 1829 B EPA
7550-45-0 titanium tetrachloride tétrachlorure de titane 1.13 1838 B EPA
7616-94-6 perchloryl fluoride fluorure de perchloryle 6.8 3083 D MIACC List #2 toxic
(trioxychlorofluorure) (trioxychlorofluoride) & OSHA
7637-07-2 boron trifluoride trifluorure de bore 2.27 1008 B EPA
7647-01-0 hydrochloric acid acide chlorhydrique 6.8 1789 B EPA
7647-01-0 hydrogen chloride, anhydrous chlorure d’hydrogène 2.27 2186 & 1050 B EPA
7664-39-3 hydrofluoric acid acide fluorhydrique 0.45 1790 B EPA
7664-39-3 hydrogen fluoride, anhydrous fluorure d’hydrogène 0.45 1052 D EC
7664-41-7 ammonia, anhydrous ammoniac 4.5 1005 B EPA
7664-41-7 ammonia solution ammoniaque solution 9.1 2073 & 2672 B EPA
7697-37-2 nitric acid acide nitrique 6.8 2031 & 2032 B EPA
7719-09-7 thionyl chloride chlorure de thionyle 6.8 1836 D MIACC List #2 toxic
& OSHA & decompose

Annex 3

CRAIM
quantity
7719-12-2 phosphorus trichloride trichlorure de phosphore 6.8 1809 B EPA

7722-84-1 hydrogen peroxide peroxyde d’hydrogène 3.4 2015 E MIACC List #2 oxidising &
(concentration 52% or greater) (concentration 52% ou plus) & OSHA reactive (explosive)
7723-14-0 phosphorus, white phosphore blanc 1 2447 F MIACC List #2 flammable
product
7726-95-6 bromine brome 4.5 1744 B EPA
7775-09-9 sodium chlorate chlorate de sodium 10 1495 E MIACC List #1 oxidising if
confined in barrel
7782-41-4 fluorine fluor 0.45 1045 B EPA
7782-50-5 chlorine chlore 1.13 1017 B EPA
7783-06-4 hydrogen sulphide sulfure d'hydrogène 4.5 1053 B EPA
7783-07-5 hydrogen selenide séléniure d'hydrogène 0.22 2202 B EPA
7783-60-0 sulphur tetrafluoride tétrafluorure de soufre 1.13 2418 B EPA
7784-34-1 arsenic trichloride trichlorure d’arsenic 6.8 1560 B EPA
7784-42-1 arsine arsine 0.45 2188 B EPA
7790-94-5 chlorosulphonic acid acide chlorosulfonique 2.27 1754 D MIACC List #2 toxic
7790-98-9 ammonium perchlorate perchlorate d’ammonium 3.4 1442 E MIACC List #2 oxydiser
& OSHA & explosive
7791-21-1 chlorine monoxide oxyde de dichlore 4.5 no number A EPA
(dichlorine oxide)
7803-51-2 phosphine phosphine 2.27 2199 B EPA
7803-52-3 stibine stibine 2.27 2676 D MIACC List #2 toxic
& OSHA & flammable
7803-62-5 silane silane 4.5 2203 A EPA
8006-14-2 natural gas gaz naturel liquéfié 4.5 1972 C MIACC List #1 flammable
8014-95-7 sulphuric acid, fuming (oleum) acide sulfurique, fumant (oléum) 4.5 1831 B EPA
8030-30-6 naphtha naphta 50 1255 & 1256 C MIACC List #1 flammable
& 2553
10025-78-2 trichlorosilane trichlorosilane 4.5 1295 A EPA
10025-87-3 phosphorus oxychloride oxychlorure de phosphore 2.27 1810 B EPA
10035-10-6 hydrogen bromide bromure d’hydrogène 1.13 1048 & 1788 D MIACC List #2 toxic
10049-04-4 chlorine dioxide dioxyde de chlore 0.45 no number B EPA
10102-43-9 nitric oxide oxyde nitrique 4.5 1660 B EPA
(monoxyde d’azote)
10102-44-0 nitrogen dioxide dioxyde d’azote 1.13 1067 D MIACC List #2 toxic
& OSHA
10294-34-5 boron trichloride trichlorure de bore 2.27 1741 B EPA
13463-39-3 nickel carbonyl nickel-tétracarbonyle 0.45 1259 B EPA
13463-40-6 iron pentacarbonyl fer pentacarbonyle 1.13 1994 B EPA
19287-45-7 diborane diborane 1.13 1911 B EPA
20816-12-0 osmium tetroxide tétroxyde d’osmium 0.22 2471 D MIACC List #2 toxic & explosive
& OSHA

Annex 3

CRAIM
quantity
25167-67-3 butylene (butene) butylène (butène) 4.5 1012 A EPA

26471-62-5 toluene diisocyanate diisocyanate de toluène 4.5 2078 B EPA
86290-81-5 gasoline (motor fuel) essence 150 1203 C MIACC List #1 flammable

Annex 3
List of Hazardous
Materials of CRAIM
by order of United Nations (UN) number

Annex 3

(by order of United Nations (UN) number)
CRAIM
quantity
UN No. English name French name (tonne) CAS No. Class Origin Remarks
1001 acetylene acétylène 4.5 74-86-2 A EPA

1005 ammonia, anhydrous ammoniac 4.5 7664-41-7 B EPA
1008 boron trifluoride trifluorure de bore 2.25 7637-07-2 B EPA
1010 1,3-butadiene butadiène-1,3 4.5 106-99-0 A EPA
1011 butane butane 4.5 106-97-8 A EPA
1012 1-butene butène-1 (butylène) 4.5 106-98-9 A EPA
1012 butylene (butene) butylène (butène) 4.5 25167-67-3 A EPA
1016 carbon monoxide monoxyde de carbone 6.8 630-08-0 D MIACC List #2
& NFPA (H=4)
1017 chlorine chlore 1.13 7782-50-5 B EPA
1026 cyanogen cyanogène 4.5 460-19-5 A EPA
1027 cyclopropane cyclopropane 4.5 75-19-4 A EPA
1030 difluoroethane difluoréthane 4.5 75-37-6 A EPA
1032 dimethylamine diméthylamine 4.5 124-40-3 A EPA
1033 dimethyl ether éther méthylique 4.5 115-10-6 A EPA
(methyl ether) (oxyde de diméthyle)
1035 ethane éthane 4.5 74-84-0 A EPA
1036 ethylamine éthylamine 4.5 75-04-7 A EPA
1037 ethyl chloride chlorure d’éthyle 4.5 75-00-3 A EPA
1038 ethylene éthylène 4.5 74-85-1 A EPA
1040 ethylene oxide oxyde d'éthylène 4.5 75-21-8 B EPA
1045 fluorine fluor 0.45 7782-41-4 B EPA
1048 hydrogen bromide bromure d’hydrogène 1.13 10035-10-6 D MIACC List #2 toxic
1049 hydrogen hydrogène 4.5 1333-74-0 A EPA
1050 hydrogen chloride, anhydrous chlorure d’hydrogène 2.27 7647-01-0 B EPA
1051 hydrogen cyanide cyanure d’hydrogène 1.13 74-90-8 B EPA
(hydrocyanic acid) (acide cyanhydrique)
1052 hydrogen fluoride, anhydrous fluorure d’hydrogène 0.45 7664-39-3 D EC
1053 hydrogen sulphide sulfure d’hydrogène 4.5 7783-06-4 B EPA
1055 2-butene butène-2 4.5 107-01-7 A EPA
1055 cis-2-butene (2-butene-cis) butène-2 cis 4.5 590-18-1 A EPA
1055 isobutylene (2-methylpropene) isobutylène 4.5 115-11-7 A EPA
1060 methylacetylene (propyne) méthylacétylène 4.5 74-99-7 A EPA
1061 methylamine méthylamine 4.5 74-89-5 A EPA
1062 methyl bromide bromure de méthyle 2.27 74-83-9 D MIACC List #2
& OSHA
1063 methyl chloride chlorure de méthyle 4.5 74-87-3 B EPA
1064 methyl mercaptan mercaptan méthylique 4.5 74-93-1 B EPA
(méthylmercaptan)
1067 nitrogen dioxide dioxyde d'azote 1.13 10102-44-0 D MIACC List #2 toxic
& OSHA
1076 phosgene phosgène 0.22 75-44-5 B EPA

Annex 3

CRAIM
quantity
1077 propylene propylène 4.5 115-07-1 A EPA

1079 sulphur dioxide dioxyde de soufre 2.27 7446-09-5 B EPA
1081 tetrafluoroethylene tétrafluoréthylène 4.5 116-14-3 A EPA
1082 trifluorochloroethylene trifluorochloréthylène 4.5 79-38-9 A EPA
1083 trimethylamine triméthylamine 4.5 75-50-3 A EPA
1086 vinyl chloride chlorure de vinyle 4.5 75-01-4 A EPA
1087 vinyl methyl ether éther méthylvinylique 4.5 107-25-5 A EPA
1089 acetaldehyde acétaldéhyde 4.5 75-07-0 A EPA
1092 acrolein acroléine 2.27 107-02-8 B EPA
1093 acrylonitrile acrylonitrile 9.1 107-13-1 B EPA
1098 allyl alcohol alcool allylique 9.1 107-18-6 B EPA
1100 allyl chloride chlorure d’allyle 0.45 107-05-1 D MIACC List #2 toxic
& OSHA & flammable
1108 1-pentene pentène-1 4.5 109-67-1 A EPA
1114 benzene benzène 10 71-43-2 C MIACC List #1 flammable
1125 tert-butylamine butylamine tertiaire 150 75-64-9 C MIACC List #2 flammable
1131 carbon disulphide disulfure de carbone 9.1 75-15-0 B EPA
1135 ethylene chlorohydrin monochlorhydrine du glycol 4.5 107-07-3 D EPA toxic
(2-chloroethanol) (chloro-2 éthanol)
1143 crotonaldehyde crotonaldéhyde 9.1 4170-30-3 B EPA
1143 trans-crotonaldehyde crotonaldéhyde trans 9.1 123-73-9 B EPA
1145 cyclohexane cyclohexane 550 110-82-7 C MIACC List #1 flammable
1155 ethyl ether (diethyl ether) éther éthylique (éther diéthylique) 4.5 60-29-7 A EPA
1160 dimethylamine diméthylamine 4.5 124-40-3 A EPA
1162 dimethyldichlorosilane diméthyldichlorosilane 2.27 75-78-5 B EPA
1163 1,1-dimethylhydrazine diméthyl-1,1 hydrazine 6.8 57-14-7 B EPA
1164 dimethyl sulphide sulfure de diméthyle 150 75-18-3 C MIACC List #2 flammable
& NFPA (F=4)
1175 ethylbenzene éthylbenzène 7000 100-41-4 C MIACC List #1 flammable
1184 1,2-dichloroethane dichlorure d’éthylène 6.8 107-06-2 D EPA toxic
1185 ethyleneimine éthylèneimine 4.5 151-56-4 B EPA
1194 ethyl nitrite nitrite d’éthyle 4.5 109-95-5 A EPA
1198 formaldehyde, solution formaldéhyde en solution 6.8 50-00-0 B EPA
1203 gasoline (motor fuel) essence 150 86290-81-5 C MIACC List #1 flammable
1218 isoprene isoprène 4.5 78-79-5 A EPA
1221 isopropylamine isopropylamine 4.5 75-31-0 A EPA
1238 methyl chloroformate chloroformiate de méthyle 2.27 79-22-1 B EPA
1239 chloromethyl methyl ether éther méthylique monochloré 2.27 107-30-2 B EPA

Annex 3

CRAIM
quantity
UN/NIP No. English name French name (tonne) CAS No. Class Origin Remarks
1243 methyl formate formiate de méthyle 4.5 107-31-3 A EPA

1244 methylhydrazine méthylhydrazine 6.8 60-34-4 B EPA
1250 methyltrichlorosilane méthyltrichlorosilane 2.27 75-79-6 B EPA
1255 naphtha naphta 50 8030-30-6 A EPA
1259 nickel carbonyl nickel-tétracarbonyle 0.45 13463-39-3 B EPA
1265 isopentane (2-methylbutane) isopentane 4.5 78-78-4 A EPA
1265 n-pentane (pentane) n-pentane (pentane) 4.5 109-66-0 A EPA
1280 propylene oxide oxyde de propylène 4.5 75-56-9 B EPA
1294 toluene toluène 2500 108-88-3 C EPA
1295 trichlorosilane trichlorosilane 4.5 10025-78-2 A EPA
1297 trimethylamine triméthylamine 4.5 75-50-3 A EPA
1298 trimethylchlorosilane triméthylchlorosilane 4.5 75-77-4 B EPA
1301 vinyl acetate acétate de vinyle 6.8 108-05-4 B EPA
1302 vinyl ethyl ether (ethyl vinyl ether) éther éthylvinylique 4.5 109-92-2 A EPA
1303 vinylidene chloride chlorure de vinylidène 4.5 75-35-4 A EPA
1307 xylenes xylènes 8000 1330-20-7 C CCAIM List #1 flammable
1442 ammonium perchlorate perchlorate d’ammonium 3.4 7790-98-9 E CCAIM List #2 oxidising et explosive
& OSHA
1495 sodium chlorate chlorate de sodium 10 7775-09-9 E CCAIM List #1 oxidising if confined
in barrel
1510 tetranitromethane tétranitrométhane 4.5 509-14-8 B EPA
1560 arsenic trichloride trichlorure d’arsenic 6.8 7784-34-1 B EPA
1580 chloropicrin chloropicrine 2.27 76-06-2 D CCAIM List #2 toxic
1589 cyanogen chloride chlorure de cyanogène 4.5 506-77-4 B EPA
1604 ethylenediamine éthylènediamine 9.1 107-15-3 B EPA
1649 tetraethyl lead plomb tétraéthyle 2.27 78-00-2 D CCAIM List #1 toxic &
flammable
1660 nitric oxide oxyde nitrique 4.5 10102-43-9 B EPA
(monoxyde d’azote)
1670 perchloromethyl mercaptan mercaptan méthylique perchloré 4.5 594-42-3 B EPA
1671 phenol phénol 9.1 108-95-2 D EPA
1741 boron trichloride trichlorure de bore 2.27 10294-34-5 B EPA
1744 bromine brome 4.5 7726-95-6 E explosive
1754 chlorosulphonic acid acide chlorosulfonique 2.27 7790-94-5 D CCAIM List #2 toxic
& NFPA (F=4) & decomposes
D = Listed toxic substance (CRAIM) E = Listed explosive substance (CRAIM) F = Listed various substance (CRAIM)

Annex 3

CRAIM
quantity
1788 hydrogen bromide bromure d’hydrogène 1.13 10035-10-6 D MIACC List #2 toxic
1789 hydrochloric acid acide chlorhydrique 6.8 7647-01-0 B EPA
1790 hydrofluoric acid acide fluorhydrique 0.45 7664-39-3 B EPA
1809 phosphorus trichloride trichlorure de phosphore 6.8 7719-12-2 B EPA
1810 phosphorus oxychloride oxychlorure de phosphore 2.27 10025-87-3 B EPA
1829 sulphur trioxide trioxyde de soufre 4.5 7446-11-9 B EPA
1831 sulphuric acid, fuming (oleum) acide sulfurique, fumant (oléum) 4.5 8014-95-7 B EPA
1836 thionyl chloride chlorure de thionyle 6.8 7719-09-7 D CCAIM List #2
& OSHA
1838 titanium tetrachloride tétrachlorure de titane 1.13 7550-45-0 B EPA
1860 vinyl fluoride fluorure de vinyle 4.5 75-02-5 A EPA
1888 chloroform (trichloromethane) chloroforme (trichlorométhane) 9.1 67-66-3 B EPA
1889 cyanogen bromide bromure de cyanogène 4.5 506-68-3 D CCAIM List #2 toxic
& NFPA (F=4)
1911 diborane diborane 1.13 19287-45-7 B EPA
1921 propyleneimine propylèneimine 4.5 75-55-8 B EPA
1959 1,1-difluoroethylene difluoro-1,1 éthylène 4.5 75-38-7 A EPA
1961 ethane éthane 4.5 74-84-0 A EPA
1962 ethylene éthylène 4.5 74-85-1 A EPA
1969 isobutane isobutane 4.5 75-28-5 A EPA
1971 methane méthane 4.5 74-82-8 A EPA
1972 natural gas gaz naturel liquéfié 4.5 8006-14-2 C MIACC List #1 flammable
1972 methane méthane 4.5 74-82-8 A EPA
1978 propane propane 4.5 74-98-6 A EPA
1994 iron pentacarbonyl fer pentacarbonyle 1.13 13463-40-6 B EPA
2015 hydrogen peroxide peroxyde d’hydrogène 3.4 7722-84-1 E MIACC List #2
(concentration 52% or greater) (concentration 52% ou plus) & OSHA
2023 epichlorohydrin épichlorhydrine 9.1 106-89-8 B EPA
2029 hydrazine hydrazine 6.8 302-01-2 B EPA
2031 nitric acid acide nitrique 6.8 7697-37-2 B EPA
2032 nitric acid acide nitrique 6.8 7697-37-2 B EPA
2044 2,2-dimethylpropane diméthyl-2,2 propane 4.5 463-82-1 A EPA
2073 ammonia solution ammoniaque solution 9.1 7664-41-7 B EPA
2078 toluene diisocyanate diisocyanate de toluène 4.5 26471-62-5 B EPA
2078 toluene-2,4-diisocyanate toluène-2,4 diisocyanate 4.5 584-84-9 B EPA
2078 toluene-2,6-diisocyanate toluène-2,6 diisocyanate 4.5 91-08-7 B EPA
2131 peroxyacetic acid (peracetic acid) acide peroxyacétique 4.5 79-21-0 B EPA

Annex 3

CRAIM
quantity
2186 hydrogen chloride, anhydrous chlorure d’hydrogène 2.27 7647-01-0 B EPA

2188 arsine arsine 0.45 7784-42-1 B EPA
2189 dichlorosilane dichlorosilane 4.5 4109-96-0 A EPA
2199 phosphine phosphine 2.27 7803-51-2 B EPA
2200 propadiene propadiène 4.5 463-49-0 A EPA
2202 hydrogen selenide séléniure d’hydrogène 0.22 7783-07-5 B EPA
2203 silane silane 4.5 7803-62-5 A EPA
2204 carbonyl sulphide sulfure de carbonyle 4.5 463-58-1 A EPA
(carbon oxysulfide)
2209 formaldehyde, solution formaldéhyde en solution 6.8 50-00-0 B EPA
2249 bis(chloromethyl) ether éther dichlorodiméthylique 0.45 542-88-1 B EPA
2270 ethylamine éthylamine 4.5 75-04-7 A EPA
2284 isobutyronitrile isobutyronitrile 9.1 78-82-0 B EPA
2334 allylamine allylamine 4.5 107-11-9 C MIACC List #1 flammable
2356 2-chloropropane chloro-2 propane 4.5 75-29-6 A EPA
2357 cyclohexylamine cyclohexylamine 6.8 108-91-8 A EPA
2363 ethyl mercaptan mercaptan éthylique 4.5 75-08-1 A EPA
2389 furan furanne 2.27 110-00-9 B EPA
2401 piperidine pipéridine 6.8 110-89-4 B EPA
2404 propionitrile propionitrile 4.5 107-12-0 B EPA
2407 isopropyl chloroformate chloroformiate d’isopropyle 6.8 108-23-6 B EPA
2418 sulphur tetrafluoride tétrafluorure de soufre 1.13 7783-60-0 B EPA
2419 bromotrifluoroethylene bromotrifluoréthylène 4.5 598-73-2 A EPA
2447 phosphorus, white phosphore blanc 1 7723-14-0 F MIACC List #2 flammable
product
2452 ethylacetylene éthylacétylène 4.5 107-00-6 A EPA
2456 2-chloropropene chloro-2 propène 4.5 557-98-2 A EPA
(2-chloropropylene)
2459 2-methyl-1-butene méthyl-2 butène-1 4.5 563-46-2 A EPA
2471 osmium tetroxide tétroxyde d’osmium 0.22 20816-12-0 D MIACC List #2 ) toxic & explosive
& OSHA
2480 methyl isocyanate isocyanate de méthyle 4.5 624-83-9 B EPA
2561 3-methyl-1-butene méthyl-3 butène-1 4.5 563-45-1 B EPA
2644 methyl iodide iodure de méthyle 4.5 74-88-4 D MIACC List #1 toxic
2073 & 2672 ammonia solution ammoniaque solution 9.1 7664-41-7 B EPA
2676 stibine stibine 2.27 7803-52-3 D MIACC List #2 toxic
& OSHA & flammable
2740 n-propyl chloroformate chloroformiate de n-propyle 6.8 109-61-5 B EPA

Annex 3

CRAIM
quantity
2749 tetramethylsilane tétraméthylsilane 4.5 75-76-3 A EPA

2809 mercury mercure 1 7439-97-6 D MIACC List #1 toxic
2965 boron trifluoride éthérate diméthylique 6.8 353-42-4 B EPA
3079 methylacrylonitrile méthacrylonitrile 4.5 126-98-7 B EPA
3083 perchloryl fluoride fluorure de perchloryle 6.8 7616-94-6 D MIACC List #2 toxic
(trioxychlorofluorure) (trioxychlorofluoride) & OSHA
no number 1-buten-3-yne (vinyl acetylene) acétylène de vinyle (butényne) 4.5 689-97-4 A EPA
no number ketene cétène 0.22 463-51-4 D MIACC List #2
& OSHA
no number 1-chloropropene chloro-1 propène 4.5 590-21-6 A EPA
(1-chloropropylene)
no number acryloyl chloride (acrylyl chloride) chlorure d’acryloyle 2.27 814-68-6 B EPA
no number chlorine dioxide dioxyde de chlore 0.45 10049-04-4 B EPA
no number chlorine monoxide oxyde de dichlore 4.5 7791-21-1 A EPA
(dichlorine oxide)
no number 1,3-pentadiene pentadiène-1,3 4.5 504-60-9 A EPA
no number cis-2-pentene (beta-cis-amylene) pentène-2 cis 4.5 627-20-3 A EPA
no number trans-2-pentene pentène-2 trans 4.5 646-04-8 A EPA
no number tetramethyl lead plomb tétraméthyle 4.5 75-74-1 B EPA
no number methyl thiocyanate thiocyanate de méthyle 9.1 556-64-9 B EPA

Guiding Principles for Joint
Municipal and Industrial
Emergency Preparedness:
Improving Community Safety
Annex
4 153
The Major Industrial Accidents Council of Canada (MIACC) wishes to acknowledge the time and
efforts dedicated by the co-chairs and members of Working Group 3 in the development of the
Guiding Principles, and to thank them for their continuing support of emergency preparedness.
Guiding Principles for Joint Municipal and Industrial Emergency Preparedness

October 1993
It is the responsibility of the user of this publication to determine the suitability of the contents for their particular use and
to implement the Guiding Principles in the manner intended.

Annex 4
Preface
J oint efforts to link municipal and industrial emergency preparedness programs will ensure
increased protection for the public, industries and the environment.
These Guiding Principles on joint municipal and industrial emergency preparedness are intend-
ed for officials in municipalities and industry. They outline the need for joint emergency pre-
paredness between municipalities and industries, and provide the foundation for establishing
the joint process.
The Guiding Principles are not intended as a guide to developing an emergency pre-
paredness program, nor as an emergency planning guide. Information on these top-
ics can be found in other documents, some of which are listed in the bibliography.
The Guiding Principles have been prepared by the Major Industrial Accidents Council of Canada
(MIACC) through a group of specialists in the emergency measures field.
The MIACC process, which is national and cooperative in scope, is dedicated to reducing the
frequency and severity of major industrial accidents involving hazardous substances.
One of MIACC’s major goals is to foster the establishment of effective links between industry
and municipalities to encourage coordinated emergency preparedness.
Readers wishing to obtain a quick overview of this publication may do so by reading the
Introduction and the bolded parts of the Guiding Principles.
For the purposes of these Guiding Principles, the use of the term “municipalities” is intended to
cover all communities in Canada including First Nations, Inuit and Metis communities.
Introduction
“It is not the lack of knowledge that causes industrial accidents, but mainly our failure
to use the knowledge that is already available.”
Background
Recent events in Canada and elsewhere underline the need for municipalities and industries to
prevent, prepare for and respond to accidents involving hazardous substances. Some recent
accidents which have caused significant loss of human life and damage to property and the
environment include:
• Mississauga, Ontario, 1979 (over 200,000 evacuated)
• Bhopal, India, 1984 (over 2,000 dead, tens of thousands injured)
• St-Basile-le-Grand, Québec, 1988 (up to 4,000 evacuated for 10 days)
• Oakville, Manitoba, 1992 (400 evacuated for 24 days)
• Ste-Elisabeth-de-Warwick, Québec, 1993 (4 firefighters killed, 8 people injured)
Accidents can occur in facilities where hazardous substances are manufactured, handled, stored
or disposed of, or during transportation. Since transportation corridors cut through almost every
municipality, risks from hazardous substances exist in all communities, whether industrial facili-
ties are located there or not. The adverse effects of accidents involving hazardous substances
can spread to adjacent communities.

Annex 4
Local governments or municipalities are responsible for assessing risks from any activity involv-
ing hazardous substances and for managing those risks. Municipalities and industries must be
prepared to respond in an effective and coordinated way to accidents which involve hazardous
substances. This can only happen in communities that are aware of potential dangers and where
officials are committed to both industrial and public safety. The public expects authorities in
municipalities and industry to be prepared to respond effectively to all emergencies.
The benefits of joint emergency preparedness are substantial. Emergency preparedness helps
to:
• ensure the safety of workers, emergency responders and the public
• reduce property damage
• reduce environmental damage
• reduce the time required for the municipality and its industry to take appropriate measures
• reduce costs and recovery delays
• inspire public confidence in authorities in industry and the public sector
• promote confidence among emergency responders in municipalities and industry
Needed—A Joint Process

Municipalities are responsible for the safety of their citizens in the event of a man-made or nat-
ural accident, while industry primarily protects the health and safety of its employees at work
sites. Both must have emergency preparedness programs; frequently, however, the two pro-
grams do not complement each other. Therefore, joint emergency preparedness is increasingly
important.
Municipalities have the responsibility to take the initiative in establishing and main-
taining effective links between municipal and industrial emergency preparedness pro-
grams.
Many municipalities have developed emergency plans in response to provincial legislation.
Similarly, industry has to comply with legislation, applicable national standards, guidelines or
codes of practice. Coordination of municipal and industrial emergency plans, however, is not
common, and joint emergency preparedness is even less common. Inadequate preparedness
increases the threat to the community.
This publication provides principles to guide municipalities and industry in developing together
a joint emergency preparedness program. Developing such a program is not a complex task.
Using the Guiding Principles will prove that the task is simple and practical.

Annex 4
1
Guiding Principles
The objective of municipalities and industry, regardless of their size or location, should
be to aim for the highest level of emergency preparedness.
Accidents involving hazardous substances can still occur despite efforts to prevent them. To
lessen the adverse effects of such accidents, municipalities and industry must be prepared to
respond to them.
The response will be more effective if municipalities and industry coordinate their emergency
preparedness programs according to these Guiding Principles.
Joint Coordinating Committee

Each municipality should promote the development of a coordinated municipal and industrial
emergency preparedness program. To achieve this joint program, a municipality and its industry
must first establish a joint coordinating committee. This can be achieved in several
ways, including:
• creating a joint committee from both the municipality and its industry
• adding officials from industry to an existing municipal committee
The committee should be formally established as the competent authority to:
• determine the risk to the community
• gather and share information
• integrate municipal and industrial emergency response plans
• identify and obtain communications equipment, systems and procedures
• develop the methods and procedures for communicating with the public and media
• develop and carry out joint training, exercises and emergency simulations
• develop mutual aid or assistance agreements
Determining the Risk

Determining risk is the first step to coordinated municipal-industrial emergency pre-
paredness. Knowing what can go wrong and the potential dangers to people, prop-
erty or the environment increases understanding and facilitates cooperation.
Risk determination should be carried out to establish the nature of existing hazards, the likeli-
hood of accidents occurring, and the nature and scope of foreseeable consequences if an acci-
dent occurs. Risk determination is only realistic if it is based on the true sharing of information.
The methods used should be credible and accepted. Current legislation and applicable standards
should also be consulted.
The results of risk determination should be written in a clear and straightforward language. The
results should be updated regularly to reflect any new risk or possible consequence, particular-
ly when changes occur to existing conditions. These changes might include new industry, new
products being manufactured, used, warehoused or transported, or changes in transportation
modes, routes or quantities of hazardous substances.
Validation by internal and external third parties would confirm the accuracy and integrity of the
risk determination results.
Some sources of further information that may help in performing risk determination are listed
in the bibliography.
1
These Guiding Principles provide the framework for joint action; they do not, however, attempt to describe complete
solutions.

Annex 4
Gathering and Sharing Information

To achieve effective cooperation, all relevant information must be shared by all partic-
ipants.
The joint coordinating committee should collect and distribute information to its members
about the following:
Acts, Regulations, By-laws and Standards
• identify all relevant federal and provincial legislative requirements and municipal by-laws
• identify all applicable standards
• consult and involve provincial emergency measures authorities
• consult industry associations to ensure that their codes of practice are met
Roles and Responsibilities
• obtain and share information on municipal and industrial emergency response
organizations, including decision-making responsibilities
• identify committee members’ specific tasks and areas of expertise
• consult and involve provincial emergency measures authorities
• review and regularly assess the effectiveness of the committee, as well as the joint
preparedness program
Resources and Mutual Aid or Assistance
• identify the resources required to meet emergency preparedness needs
• share information concerning resources that can be made available in emergencies
• develop an inventory of equipment and qualified individuals, agencies or organizations
capable of providing emergency services
• ensure that the inventory lists include names, addresses, telephone and fax numbers,
as well as the procedures for activating these services
• regularly update the inventories of required and available resources
• share information on existing third-party service contracts
Emergency Response Plans

Complementary municipal and industrial emergency response plans will minimize the
effects of an accident. These plans should cover all the elements required to prepare
communities for emergency situations.
Municipal and industrial emergency response plans will describe the actions to be taken in order
to minimize the effects of an emergency. This includes protecting human life and reducing dam-
age to property and the environment.
Problems that arise during an emergency should be noted for future resolution.
When comparing and discussing municipal and industrial emergency response plans, the joint
coordinating committee should pay particular attention to the following:
Limiting the Impact on Health, Property and the Environment
A coordinated response to an emergency can limit loss of life, injuries, or damage to property,
and environmental deterioration.
Identification of Roles and Responsibilities
It is essential to clearly identify the roles and responsibilities of responders in municipalities and
industry, and the decision-making hierarchy. As well, the means of communication between all
parties must be clearly spelled out. Any operational problems related to the sharing of roles and
responsibilities should be resolved by the joint coordinating committee before joint planning is
finalized. Failure to do so will weaken the joint emergency response.

Annex 4
Activating the Response

Procedures should be clearly established for activating a joint response and dealing with emer-
gency calls. A list of names and telephone numbers of persons and their back-ups from indus-
try and the municipality who may need to be contacted in an emergency should be developed
and regularly updated.
Recovery
It is to the advantage of authorities in municipalities and industry to plan a prompt and organ-
ized return to normal conditions.
The joint coordinating committee can hasten the process of recovery by determining shared
responsibilities and activities in the areas of: damage assessment; cleanup; health and safety;
stress management; and business and public service resumption. Problems that arose during the
emergency should be resolved.
Communications Equipment, Systems and Procedures

Handling emergencies requires effective communications systems, equipment and
procedures. Establishing and maintaining prompt and uninterrupted communications,
despite the worst conditions that may occur during a disaster, is critical.
Effective communications encompass both the equipment needed to communicate, and proce-
dures ensuring efficient sharing of appropriate information. Both are necessary for effective deci-
sion-making.
Authorities in municipalities and industry should develop a plan which covers the equipment
needed, and the procedures for communicating between themselves, with the public directly
involved, and with the public at large.
Emergency communications plans should provide for alternate communications equipment and
systems to ensure the security and continuity of oral and written communications, even in the
worst conditions. As well, there should be a back-up system with its own built-in alternatives.
Responders must know in advance with whom they must communicate and the types of equip-
ment to use. Procedures, codes and instructions should be developed to gather and transmit
general information and to issue instructions.
Communication with the Public and the Media

The public has the right to be informed of risks to which it might be exposed.
Residents need to be warned of any emergency and informed about what steps to
take to protect themselves and their property. Community awareness will lead to
improved public cooperation in the event of an emergency.
Effective communications systems are essential to warn the public that an accident or natural
disaster is imminent or has taken place.
Keeping the public informed about joint industrial and municipal preparedness will encourage
them to react positively to emergency preparedness activities, response exercises and related
programs. Communications with the public should be a regular occurrence when operating
under normal conditions. When danger is imminent, the public must be warned immediately,
and given frequent information updates during an emergency. The public should also be
informed about any consequences of an accident.

Annex 4
During Normal Operations

Industry should be pro-active in letting surrounding communities know about the nature of their
operations and the potential risks involved. Regular information updates will ensure effective
and credible communications if an emergency arises.
The joint coordinating committee should:
• identify the population at risk
• identify the most practical way of communicating with the population at risk
• inform the media of the means of communication that will be used if an accident occurs
• publicize the means of communication
• ensure that credible and knowledgeable communicators are designated to act as
spokespersons in emergencies
• ensure that relations and effective communications with the media are established
The Emergency Alert
The media and the public should be warned as quickly as possible when an emergency situa-
tion warrants. They should be informed also about what steps to take, the frequency of infor-
mation updates, and where to get more information.
During an Emergency
Communications with the media and the public, when an accident occurs, should cover:
• a description of the accident
• the hazardous substances involved and their effects
• possible consequences
• a report on the measures that have been taken
• additional information on what actions to take
This information should be updated frequently throughout the emergency.
Post-Emergency
The public should be informed of the consequences of the emergency, its long term effects, and
steps that will be taken to avoid a repetition of such accidents.
Joint Training, Exercises and Emergency Simulations

Joint training, exercises and emergency simulations are an important part of joint
emergency preparedness programs.
Training
When responders acquire adequate training, knowledge and experience, they feel more confi-
dent in their abilities. Joint training develops responders’ confidence in the skills and abilities of
their team-mates. Increased confidence builds a stronger team and increases mutual trust and
cooperation.
Officials in municipalities and industry should ensure that responders receive training that will
provide the adequate knowledge and skills for the duties they will be required to perform. This
will facilitate the coordination of the various functions of team members.
Cooperative training is the preferred approach to emergency response training. Joint training
should emphasize the shared roles and responsibilities identified by the joint coordinating com-
mittee. External resource agencies that may be called upon to provide emergency response
should be made aware of specific dangers so that they may adequately train their personnel.

Annex 4
Exercises and Emergency Simulations

No plan is valid until it is put to the test. Joint exercises and emergency simulations
allow all parts of a joint emergency program to be validated and improved.
In designing joint training exercises and emergency simulations, the following points should be
observed:
• All potential emergency situations should be simulated as realistically as possible
• Emergency simulations should increase in complexity as experience is gained
• Observers should be used to spot deficiencies and opportunities for improvement
• All communications equipment, systems and procedures should be thoroughly tested
Difficulties that arise during an exercise or simulation should be noted for future resolution.
Mutual Aid or Assistance Agreements

Mutual aid or assistance agreements provide for both stronger ties between a munic-
ipality and its industry (or between neighbouring municipalities), and a shared under-
standing of the risks and levels of preparedness.
Given the number of elements that must be considered in joint emergency preparedness, and
the numerous advantages from establishing and maintaining clear links, an agreement outlin-
ing the cooperative process between a municipality and its industry is advisable.
The agreement should cover:
• information to be exchanged
• human and material resources to be made available
• availability of third parties to respond
• how aid is to be requested
• responsibilities of the parties
• insurance coverage, indemnity clauses, etc.
• how costs are to be shared
The joint coordinating committee should regularly assess the effectiveness of mutual aid pro-
grams, and update them regularly.
Conclusion
Emergency preparedness is an ongoing process. Joint emergency preparedness pro-
grams should be reviewed and revised regularly to ensure that effective emergency
preparedness exists in a municipality at all times.

Annex 4
Bibliography
Baram, M.S., P.S. Dillon and B. Ruffle, Managing Chemical Risks: Corporate Response to SARA
Title III. The Center for Environmental Management, Tufts University, Medford, Massachusetts,
1990. 258 p.
Canadian Chemical Producers’ Association, Blue Book on Responsible Care: A Total
Commitment, Ottawa, Ontario, 1992.
Canadian Chemical Producers’ Association, Community Awareness and Emergency Response
Implementation Guide, Ottawa, Ontario, 1986. 84 p.
Canadian Standards Association CAN/CSA Z731, Emergency Planning for Industry, Toronto,
Ontario, 1991. 57 p.
Canadian Standards Association CAN/CSA 634, Risk Analysis, Toronto, Ontario, 1991.
Emergency Preparedness Canada, A Concept of Operations for Emergency Site Management,
Ottawa, Ontario, n. d. 36 p.
Emergency Preparedness Canada, Procedures for the Coordination of Crisis Management
Operations, Ottawa, Ontario, 1981. 12 p.
Everson, Peter R., A Selective Review of Information Technology and its Application to
Emergency Planning and Response. Ottawa, Ontario, 1986. 81 p.
Gow, H.B.F. and R.W. Kay, Emergency Planning for Industrial Hazards, Commission of the
European Communities, Elvesier Applied Science, London, England, and New York, N.Y., 1988.
387 p.
Gow, H.B.F. and H. Otway, Communicating with the Public about Major Accident Hazards,
Elvesier Applied Science, New York, N.Y., 1990. 623 p.
Harrald, John R. et al., “’We were always re-organizing…’: some Crisis management implica-
tions of the Exxon Valdez oil spill”, Industrial Crisis Quarterly, 1992.
Industrial and Environmental Office, Awareness and Preparedness for Emergencies at Local Level
(APELL), A Process for Responding to Technological Accidents, United Nations Environment
Programme, Paris, 1988. 63 p.
International Labour Office, Prevention of Major Industrial Accidents (Code of Practice), Geneva,
1991. 108 p.
Major Industrial Accidents Council of Canada, A Training Review and Development Criteria–
Guidelines for Emergency Response Training, Ottawa, Ontario, 1993.
Major Industrial Accidents Council of Canada, Emergency Response Training Inventory (1st
Edition), Ottawa, Ontario, 1992. 170 p.
Major Industrial Accidents Council of Canada, Emergency Response Training Inventory (electron-
ic format) (1st Edition), Ottawa, Ontario, 1993.
Organisation for Economic Co-operation and Development, Guiding Principles for Chemical
Prevention, Preparedness and Response, Guidance for Public Authorities, Industry, Labour and
Others for the Establishment of Programmes and Policies Related to Prevention of, Preparedness
for, and Response to Accidents Involving Hazardous Substances, OECD, Paris. 124 p.

Annex 4
For more information on emergency preparedness programs in your province, please

contact the following Emergency Measures Organizations, or the Regional Director of
the Office of Critical Infrastructure Protection and Emergency Preparedness
(Emergency Preparedness Canada) in your region:
Alberta
Disaster Services
Alberta Municipal Affairs
16D, Commerce Place
10155 - 102 Street, NW
Edmonton, Alberta T5J 4L4
Tel.: (780) 427-8711
Fax: (780) 422-149
British Columbia
Provincial Emergency Program
455 Boleskine Road
Victoria, British Columbia V8Z 1E7
Tel.: (250) 952-4913
Fax: (250) 952-4888
Manitoba
Manitoba Emergency Measures Organization
1510- 405 Broadway
Winnipeg, Manitoba R3C 3L6
Tel.: (204) 945-8855
Fax: (204) 945-4620
New Brunswick
New Brunswick Public Safety Services
Department of Municipalities, Culture and Housing
P.O. Box 6000
65, Brunswick Street
Fredericton, New-Brunswick E3B 1C5
Tel.: (506) 453-2133
Fax: (506) 453-5513
Newfoundland
Emergency Measures Division
Department of Municipal & Provincial Affairs
50 Parade Street
St. John’s, Newfoundland A1B 4J6
Tel.: (709) 729-3703
Fax: (709) 729-3857

Annex 4
Northwest Territories
Emergency Measures Organization
Department of Municipal and Community Affairs
Government of the Northwest Territories
600 - 5201 Avenue 50
Yellowknife, Northwest Territories X1A 3S9
Tel.: (867) 920-6133
Fax: (867) 873-8193
Nova Scotia
Emergency Measures Organization (N.S.)
21 Mount Hope Avenue, 2nd Floor
Dartmouth, Nova Scotia B3J 1A1
Tel.: (902) 424-5620
Fax: (902) 424-5376
Nunavut
Nunavut Emergency Services
Department of Community Government and Transport
Government of Nunavut
P.O. Box 1000, Station 700
Igaluit, Nunavut X0A 0H0
Tel.: (867) 975-5316
Fax: (867) 979-4221
Ontario
Emergency Measures Ontario
1 St. Clair, 7th Floor
Toronto (Ontario) M7A 1K6
Tel.: (416) 212-3455
Fax: (416) 212-3498
Prince Edward Island

Emergency Measures Organization
P.O. Box 2000
Charlottetown (Prince Edward Island) C1A 5L2
Tel.: (902) 888-8050
Fax: (902) 888-8054

Annex 4
Québec
Direction générale de la Sécurité civile
Ministère de la Sécurité publique
2525, boulevard Laurier, 6ème étage
Sainte-Foy (Québec) G1V 2L2
Tel.: (418) 643-3256
Fax: (418) 646-0910
Saskatchewan
Saskatchewan Emergency Planning
100 - 1855 Victoria Avenue
Regina (Saskatchewan) S4P 3V7
Tel.: (306) 787-9563
Fax: (306) 787-1694
Yukon
Emergency Measures Branch
Department of Community and Transportation Services
Government of Yukon
P.O. Box 2703
Whitehorse (Yukon) Y1A 2C6
Tel.: (867) 667-5220
Fax: (867) 393-6266
These Guiding Principles are endorsed by:

Canadian Association of Chiefs of Police
Canadian Association of Fire Chiefs
Canadian Association of Petroleum Producers
Canadian Chemical Producers’ Association
Canadian Energy Pipeline Association
Canadian Confederation of Ambulance Service Associations
Council of Ministers Responsible for Emergency Preparedness
Federation of Canadian Municipalities
Government of Alberta
Government of British Columbia
Government of Canada
Government of Manitoba
Government of Newfoundland and Labrador
Government of New Brunswick
Government of North West Territories
Government of Nova Scotia
Government of Ontario
Government of Prince Edward Island
Government of Québec
Government of Saskatchewan
Government of Yukon
Insurance Bureau of Canada
Mining Association of Canada
Railway Association of Canada

Excerpts from
the EPA document
“General Guidance for Risk
Management Programs”
from United States Environmental Protection Agency
(EPA)
Annex
5 167
Annex 5
Note:
This annex consists of excerpts from the “General Guidance for Risk Management Programs”
document of the U.S. Environmental Protection Agency (EPA 550-B-00- 008, May 2000). All the
references contained in this annex thus pertain to this document.

Annex 5
CHAPTER 1
GENERAL APPLICABILITY
1.1 Introduction
T he purpose of this chapter is to help you determine if you are subject to part 68, the risk
management program rule.
Part 68 covers you if you are:
• The owner or operator of a stationary source (facility)
• That has more than a threshold quantity
• Of a regulated substance
• In a process.
The goal of this chapter is to make it easy for you to identify processes that are covered by this
rule so you can focus on them.
This chapter walks you through the key decision points (rather than the definition items above),
starting with those provisions that may tell you that you are not subject to the rule. We first out-
line the general applicability provisions and the few exemptions and exclusions, then discuss
which chemicals are “regulated substances.” If you do not have a “regulated substance” at
your site, you are not covered by this rule. The exemptions may exclude you from the rule or
simply exclude certain activities from consideration. (Throughout this document, when we say
“rule” we mean the regulations in part 68.)
We then describe what is considered a “process,” which is critical because you are subject to
the rule only if you have more than a threshold quantity in a process. The chapter next describes
how to determine whether you have more than a threshold quantity.
Finally, we discuss how you define your overall stationary source and when you must comply.
These questions are important once you have decided that you are covered. For most facilities
covered by this rule, the stationary source is basically all covered processes at your site. If your
facility is part of a site with other divisions of your company or other companies, the discussion
of stationary source will help you understand what you are responsible for in your compliance
and reporting.
Exhibit 1-1 presents the decision process for determining applicability.
State Programs
This guidance applies to only 40 CFR part 68. You should check with your state government to
determine if the state has its own accidental release prevention rules or has obtained delegation
from EPA to implement and enforce part 68 in your state. State rules may be more stringent
than EPA’s rules. Unless your state has been granted delegation, you must comply with part 68
as described in this document even if your state has different rules under state law. See Chapter
10 for a discussion of state implementation of part 68.

Annex 5
Exhibit 1-1
Evaluate Facility to Identify Covered Processes
Is your facility a No
stationary
source?
Yes
Do you have any No

regulated
substances?
Yes 1
STOP!
Define your You are not covered
processes by the rule
Do you have
any regulated
substances No
above a
threshold
quantity in a
process?
Yes
You are subject

to the rule
Assign Program levels

to covered processes
(see Exhibit 2-1)
1
Note: Certain substances or situations other than those identified and described in this guide may be the source of
significant risks. It is the responsibility of each facility to guard against accidents and to report to its municipality all
risks that could have consequences off-site, even if these risks are not covered by the present guide.

Annex 5
1.2 General Provisions

The CAA applies this rule to any person who owns or operates a stationary source. “Person” is
defined to include
“An individual, corporation, partnership, association, State, municipality, political subdivision of
a state, and any agency, department, or instrumentality of the United States and any officer,
agency, or employee thereof.”
The rule, therefore, applies to all levels of government as well as private businesses.
CAA section 112(r)(2)(c) defines “stationary sources” as:
“Any buildings, structures, equipment, installations, or substance emitting stationary activities
• Which belong to the same industrial group,
• Which are located on one or more contiguous properties,
• Which are under the control of the same person (or persons under common control),
and
• From which an accidental release may occur.”
EPA has added some language in the rule to clarify issues related to transportation (see below).
Farms (§ 68.125)
The rule has only one exemption: for ammonia when held by a farmer for use on a farm. This
exemption applies to ammonia only when used as a fertilizer by a farmer. It does not apply to
agricultural suppliers or the fertilizer manufacturer. It does not apply to farm cooperatives or to
groups of farmers who buy, use, and sell ammonia. In the event that a farmer stores one or
more other regulated substance above threshold quantities, that storage would be covered.
Flammable Fuels (§ 68.126)

The flammable substances listed in § 68.130 are excluded from coverage under part 68 when
they are used as a fuel or held for sale as a fuel at a retail facility. A retail facility is defined as a
stationary source at which more than half of the income is obtained from direct sales to end
users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder
exchange program. Unless your facility meets the definition of a “retail facility,” if you hold a
listed flammable substance for purposes other than on-site use as fuel, you are potentially cov-
ered by part 68. For example, if you manufacture a listed flammable fuel, use it as a chemical
feedstock, or store it in bulk for sale and do not meet the definition of a retail facility, you may
be covered by the rule. If you store a listed flammable substance for non-fuel use and also use
some of it on-site as a fuel, the quantity used as a fuel is not covered; the quantity not used on
site as a fuel is potentially subject to the rule. If you are a retailer who sells a flammable fuel and
a listed toxic substance, the toxic substance is potentially subject to the rule, but the flammable
substance is excluded from coverage.
Transportation Activities
The rule applies only to stationary sources. Pipelines covered by DOT or under a state natural gas
or hazardous liquid program for which the state has in effect a certification to DOT under 49
U.S.C. 6010.5 are not covered. Piping at your source, however, is covered. Storage of natural
gas incident to transportation (i.e., gas taken from a pipeline during non-peak periods and
placed in storage fields, then returned to the pipeline when needed) is not covered. Storage
fields include, but are not limited to, depleted oil and gas reservoirs, aquifers, mines, or caverns.
Liquefied natural gas facilities covered by 49 CFR part 193 are not covered.

Annex 5
Transportation containers used for storage not incident to transportation and transportation
containers connected to equipment at a stationary source are considered part of the stationary
source. Transportation containers that have been unhooked from the motive power that deliv-
ered them to the site (e.g., truck or locomotive) and left on your site for short-term or long-term
storage are part of your stationary source. For example, if you have railcars on a private siding
that you use as storage tanks until you are ready to hook them to your process, these railcars
should be considered to be part of your source. If a tank truck is being unloaded and the motive
power is still attached, the truck and its contents are considered to be in transportation and not
covered by the rule. You should count only the substances in the piping or hosing as well as the
quantity unloaded. Some issues related to transportation are still under discussion with DOT.
Qs & As
Stationary Source
Q. What does “same industrial group” mean?

A. Operations at a site that belong to the same three-digit North American Industry
Classification System (NAICS) code (which has replaced the old two-digit SIC codes) belong
to the “same industrial group.” In addition, where one or more operations at the site serve
primarily as support facilities for the main operation at the site, the supporting operations
are part of the “same industrial group” as the main operation. For example, if you manu-
facture chemicals (NAICS 325) and operate a waste treatment facility (NAICS 562) that han-
dles primarily wastes generated by your chemical operations, the waste operation would
be considered a support operation. If you operate a petrochemical manufacturing opera-
tion (NAICS 32511) next to your petroleum refinery (NAICS 32411), the two plants would
be considered in different industrial groups and would require two RMPs unless the major-
ity of the refinery’s production was used by the chemical manufacturing plant.
Q. What does “contiguous property” mean?

A. Property that is adjoining. Public rights-of-way (e.g., railroads, highways) do not prevent
property from being considered contiguous. Property connected only by rights-of-way are
not considered contiguous (e.g., two plants with a connecting pipeline).
Q. What does “control of the same person” mean?

A. Control of the same person refers to corporate control, not site management. If two divi-
sions of a corporation operate at the same site, even if each operation is managed sepa-
rately, they will count as one source provided the other criteria are met because they are
under control of the same company.

Annex 5
Relationship to OSHA Process Safety

Management Standard Exemptions
The OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) exempts retail facil-
ities, substances used solely as a fuel if such substances are not part of a process containing
another regulated substance, flammable liquids stored in atmospheric storage tanks, oil and gas
well drilling and services, and normally unoccupied remote facilities; in addition, state and local
governments are not subject to federal OSHA standards. The OSHA exemptions do not apply
or extend to EPA’s Risk Management Program Rule. Your processes are not exempt from the Risk
Management Program simply because they qualify for one of the OSHA exemptions. EPA’s rule
covers retail facilities handling regulated toxics, substances stored in atmospheric storage tanks,
and state and local governments if they own or operate a facility where there is more than a
threshold quantity in a process. As discussed in Section 1.5, most oil and gas production facili-
ties as well as retail gas stations are not subject to the rule because the flammables are exclud-
ed from threshold determinations. As discussed above, flammable substances are excluded
when used as fuels or held by a retail facility for sale to end users. Unlike OSHA, EPA excludes
flammable substances used as a fuel even if they are used in a process that contains other reg-
ulated substances.
1.3 Regulated Substances and Thresholds (§ 68.130)

The list of substances regulated under § 68.130 is in Federal Register, vol. 61, no. 120/Thrusday,
June 20, 1996, Rules and Regulations. Check the list carefully. If you do not have any of these
substances (either as pure substances or in mixtures above 1 percent concentration) or do not
have them above their listed threshold quantities, you do not need to read any further because
you are not covered.
The list includes 77 chemicals that were listed because they are acutely toxic; they can cause seri-
ous health effects or death from short-term exposures. The list also covers 63 flammable gases
and highly volatile flammable liquids. The flammable chemicals have the potential to form vapor
clouds and explode or burn if released. The rule also covers flammable mixtures that include any
of the listed flammables if the mixture meets the criteria for the National Fire Protection
Association’s (NFPA) 4 rating.
1.4 What Is a Process?

The concept of “process” is key to whether you are subject to this rule. Process is defined in 40
CFR § 68.3 as:
“Any activity involving a regulated substance including any use, storage, manufacturing, han-
dling, or on-site movement of such substances, or combination of these activities. For the pur-
poses of this definition, any group of vessels that are interconnected, or separate vessels that are
located such that a regulated substance could be involved in a potential release, shall be con-
sidered a single process.”
“Vessel” in § 68.3 means any reactor, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose,
or other container.

Annex 5
EPA’s definition of process is identical to the definition of process under the OSHA PSM stan-
dard. Understanding the definition of process is important in determining whether you have a
threshold quantity of a regulated substance and what level of requirements you must meet if
the process is covered.
What does this mean to you?
• If you store a regulated substance in a single vessel in quantities above the threshold quanti-
ty, you are covered.
• If you have interconnected vessels that altogether hold more than a threshold quantity, you
are covered. The connections need not be permanent. If two or more vessels are connected
occasionally, they are considered a single process for the purposes of determining whether a
threshold quantity is present.
• If you have multiple unconnected vessels, containing the same substance, you will have to
determine whether they need to be considered together as co-located.
A process can be as simple as a single storage vessel or a group of drums or cylinders in one
location or as complicated as a system of interconnected reactor vessels, distillation columns,
receivers, pumps, piping, and storage vessels.
Single Vessels
If you have only a single vessel containing regulated substances, you need not worry about the
other possibilities for defining a process and can skip to Section 1.5. For the purposes of defin-
ing a threshold quantity, you need only consider the quantity in this vessel.
Interconnected Vessels
In general, if you have two or more vessels containing a regulated substance that are connect-
ed through piping or hoses for the transfer of the regulated substance, you must consider the
total quantity of a regulated substance in all the connected vessels and piping when determin-
ing if you have a threshold quantity in a process. If the vessels are connected for transfer of the
substance using hoses that are sometimes disconnected, you still have to consider the contents
of the vessels as one process, because if one vessel were to rupture while the hose was attached
or the hose were to break during the transfer, both tanks could be affected. Therefore, you must
count the quantities in both tanks and in any connecting piping or hoses. You cannot consider
the presence of automatic shutoff valves or other devices that can limit flow, because these are
assumed to fail for the purpose of determining the total quantity in a process.
Once you have determined that a process is covered (the quantity of a regulated substance
exceeds its threshold), you must also consider equipment, piping, hoses, or other interconnec-
tions that do not carry or contain the regulated substance, but that are important for acciden-
tal release prevention. Equipment or connections which contain utility services, process cooling
water, steam, electricity, or other non-regulated substances may be considered part of a process
if such equipment could cause a regulated substance release or interfere with mitigating the
consequences of an accidental release. Your prevention program for this process (e.g., PSM pro-
gram) will need to cover such equipment. If, based on your analysis, it is determined that inter-
connected equipment or connections not containing the regulated substance cannot cause a
regulated substance release or interfere with mitigation of the consequences of such a release,
then such equipment or connections could safely be considered outside the limits or boundaries
of the covered process.

Annex 5
In some cases, such as in a large refinery or multi-unit chemical plant, determining the bound-
aries of a process for purposes of the RMP rule may be complicated. In the preamble to the June
20, 1996 rule (61 FR 31668), EPA clearly stated its intent to be consistent with OSHA’s interpre-
tation of “process” as that term is used in OSHA’s PSM rule. Therefore, if your facility is subject
to the PSM rule, the limits of your process(es) for purposes of OSHA PSM will be the limits of
your process(es) for purposes of RMP (except in cases involving atmospheric storage tanks con-
taining flammable regulated substances, which are exempt from PSM but not RMP). If your facil-
ity is not covered by OSHA PSM and is complicated from an engineering perspective, you should
consider contacting your implementing agency for advice on determining process boundaries.
Co-location
The third possibility you must consider is whether you have separate vessels that contain the
same regulated substance that are located such that they could be involved in a single release.
If so, you must add together the total quantity in all such vessels to determine if you have more
than a threshold quantity. This possibility will be particularly important if you store a regulated
substance in cylinders or barrels or other containers in a warehouse or outside in a rack. In some
cases, you may have two vessels or systems that are in the same building or room. For each of
these cases, you should ask yourself:
• Could a release from one of the containers lead to a release from the other? For example, if
a cylinder of a flammable substance were to rupture and burn, would the fire spread to
other cylinders?
• Could an event external to the containers, such as a fire or explosion or collapse or collision
(e.g., a vehicle collides with several stored containers), have the potential to release the reg-
ulated substance from multiple containers?
You must determine whether there is a credible scenario that could lead to a release of a thresh-
old quantity.
For flammables, you should consider the distance between vessels. If a fire could spread from
one vessel to others or an explosion could rupture multiple vessels, you must count all of them.
For toxics, a release from a single vessel will not normally lead to a release from others unless
the vessel fails catastrophically and explodes, sending metal fragments into other vessels. Co-
located vessels containing toxic substances, however, may well be involved in a release caused
by a fire or explosion that occurs from another source. The definition of process is predicated on
the assumption that explosion will take place. In addition, a collapse of storage racks could lead
to multiple vessels breaking open.
If the vessels are separated by fire walls or barricades that will contain the blast waves from
explosions of the substances, you will not need to count the separated vessels, but you would
count any that are in the same room.
You may not dismiss the possibility of a fire spreading based on an assumption that your fire
brigade will be able to prevent any spread. You should ask yourself how far the fire would
spread if the worst happens— he fire brigade is slow to arrive, the water supply fails, or the local
fire department decides it is safer to let the fire burn itself out. If you have separate vessels con-
taining a regulated substance that could be affected by the same accident, you should count
them as a single process.

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Processes with Multiple Chemicals

When you are determining whether you have a covered process, you should not limit your con-
sideration to vessels that have the same regulated substance. A covered process includes any
vessels that altogether hold more than a threshold quantity of regulated substances and that
are interconnected or co-located. Therefore, if you have four storage or reactor vessels holding
four different regulated substances above their individual thresholds and they are located close
enough to be involved in a single event, they are considered a single process. One implication
of this approach is that if you have two vessels, each containing slightly less than a threshold
quantity of the same regulated substance and located a considerable distance apart, and you
have other storage or process vessels in between with other regulated substances above their
thresholds, the two vessels with the first substance may be considered to be part of a larger
process involving the other intervening vessels and other regulated substances, based on co-
location.
Exhibit 1-2 provides illustrations of what may be defined as a process.
Differences with OSHA

OSHA aggregates different flammable liquids across vessels in making threshold determinations;
OSHA also aggregates different flammable gases (but does not aggregate flammable liquids
with flammable gases); EPA aggregates neither. Therefore, if you have three co-located or con-
nected reactor vessels each containing 5,000 pounds of a different flammable liquid, OSHA con-
siders that you have 15,000 pounds of flammable liquids and are covered by the PSM standard.
Under EPA’s rule, you would not have a covered process because you do not meet the thresh-
old quantity for any one of the three substances. OSHA, like EPA, does not aggregate quanti-
ties for toxics as a class (i.e., each toxic substance must meet its own threshold quantity).
1.5 Threshold Quantity in a Process

The threshold quantity for each regulated substance is listed in 40 CFR § 68.30, in Appendix A.
You should determine whether the maximum quantity of each substance in a process is greater
than the threshold quantity listed. If it is, you must comply with this rule for that process. Even
if you are not covered by this rule, you may still be subject to reporting requirements under the
Emergency Planning and Community Right to Know Act (EPCRA).
Quantity in a Vessel
To determine if you have the threshold quantity of a regulated substance in a vessel involved in
a single process, you need to consider the maximum quantity in that vessel at any one time. You
do not need to consider the vessel’s maximum capacity if you never fill it to that level. Base your
decision on the actual maximum quantity that you may have in the vessel. Your maximum quan-
tity may be more than your normal operating maximum quantity; for example, if you may use
a vessel for emergency storage, the maximum quantity should be based on the quantity that
might be stored.

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Exhibit 1-2
Processes
Schematic Representation Description Interpretation
1 vessel
1 regulated substance above TQ 1 process
2 or more connected vessels

same regulated substance 1 process
above TQ
2 or more connected vessels

different regulated substances 1 process
each above TQ
pipeline feeding multiple 1 process

vessels total above TQ
2 or more vessels co-located

same substance 1 process
total above TQ
2 or more vessels co-located

different substances 1 process
each above TQ
2 vessels, located so they won’t be

involved in a single release 2 processes
same or different substances
each above TQ
2 locations with regulated 1 or 2 processes

substances depending
each above TQ on distance
1 series of interconnected vessels

same or different substances
above TQs plus a 1 process
flammable co-located storage vessel
containing flammables

Annex 5
Aggregation of Substances
A toxic substance is never aggregated with a different toxic substance to determine whether a
threshold quantity is present. If your process consists of co-located vessels with different toxic
substances, you must determine whether each substance exceeds its threshold quantity.
A flammable substance in one vessel is never aggregated with a different flammable substance
in another vessel to determine whether a threshold quantity is present. However, if a flamma-
ble mixture meets the criteria for NFPA-4 and contains different regulated flammables, it is the
mixture, not the individual substances, that is considered in determining if a threshold quantity
is present.
“At any one time” means you need to consider the largest quantity that you ever have in the
vessel. If you fill a tank with 50,000 pounds and immediately begin using the substance and
depleting the contents, your maximum is 50,000 pounds.
If you fill the vessel four times a year, your maximum is still 50,000 pounds. Throughput is not
considered because the rule is concerned about the maximum quantity you could release in a
single event.
Quantity in a Pipeline
The maximum quantity in a pipeline will generally be the capacity of the pipeline (volume). In
most cases, pipeline quantity will be calculated and added to the interconnected vessels.
Interconnected/Co-located Vessels
If your process consists of two or more interconnected vessels, you must determine the maxi-
mum quantity for each vessel and the connecting pipes or hoses. The maximum for each indi-
vidual vessel and pipe is added together to determine the maximum for the process.
If you have determined that you must consider co-located vessels as one process, you must
determine the maximum quantity for each vessel and sum up the quantities of all such vessels.
Quantity of a Substance in a Mixture

Toxics with listed concentration
Four toxic substances have listed concentrations in the rule: hydrochloric acid—37 percent or
greater; hydrofluoric acid—50 percent or greater; nitric acid—80 percent or greater; and ammo-
nia—20 percent or greater.
• If you have these substances in solution and their concentration is less than the listed concen-
tration, you do not need to consider them at all.
• If you have one of these four above their listed concentration, you must determine the weight
of the substance in the solution and use that to calculate the quantity present. If that quanti-
ty is greater than the threshold, the process is covered. For example, aqueous ammonia is cov-
ered at concentrations above 20 percent, with a threshold quantity of 20,000 pounds. If the
solution is 25 percent ammonia, you would need 80,000 pounds of the solution to meet the
threshold quantity; if the solution is 44 percent ammonia, you would need 45,455 pounds to
meet the threshold quantity (quantity of mixture x percentage of regulated substance = quan-
tity of regulated substance).
Note that in a revision to part 68, EPA changed the concentration for hydrochloric acid to 37
percent or greater (see Appendix A).

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Toxics without a listed concentration

For toxics without a listed concentration, if the concentration is less than one percent you need
not consider the quantity in your threshold determination. If the concentration in a mixture is
above one percent, you must calculate the weight of the regulated substance in the mixture and
use that weight to determine whether a threshold quantity is present. However, if you can meas-
ure or estimate (and document) that the partial pressure of the regulated substance in the mix-
ture is less than 10 mm Hg, you do not need to consider the mixture. Note that the partial pres-
sure rule does not apply to toluene diisocyanate (2,4-, 2,6- or mixed isomers) or oleum.
EPA treats toxic mixtures differently from OSHA. Under the OSHA PSM standard, the entire
weight of the mixture is counted toward the threshold quantity; under part 68, only the weight
of the toxic substance is counted.
Qs & As
Process
Q. Do I have to do my hazard review, process hazard analysis, or other prevention activ-

ity on the whole process or can I break it into separate units?
A. Once you have determined that you have a covered process, you can divide the covered
process any way you want to implement the prevention program. If you have multiple inter-
connected storage and reactor vessels in your process, you may want to treat them sepa-
rately when you conduct the hazard review or process hazard analysis, if only to make the
analyses easier to manage. Storage and reactor vessels may require separate maintenance
programs. You should do what makes sense for you.
Q. How far apart do separate vessels have to be to be considered different processes?

A. There is no hard and fast rule for how great this distance should be before you do not
need to consider the vessels as part of one process. Two vessels at opposite ends of a large
warehouse room might have to be considered as one process if the entire warehouse or
room could be engulfed in a fire. Two vessels separated by the same distance out of doors
might be far enough apart that a fire affecting one would be unlikely to spread to the other.
You may want to consult with your local fire department. You should then use your best
professional judgment. Ask yourself how much of the regulated substance could be
released if the worst happens (you have a major fire, an explosion, a natural disaster).

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Flammables
Flammable mixtures are subject to the rule only if there is a regulated substance in the mixture
above one percent and the entire mixture meets the NFPA-4 criteria. If the mixture meets both
of these criteria, you must use the weight of the entire mixture (not just the listed substance) to
determine if you exceed the threshold quantity. The NFPA-4 definition is as follows:
“Materials that will rapidly or completely vaporize at atmospheric pressure and normal ambient
temperature or that are readily dispersed in air, and that will burn readily. This degree usually
includes:
Flammable gases
Flammable cryogenic materials
Any liquid or gaseous material that is liquid while under pressure and has a flash point below
73ºF (22.8ºC) and a boiling point below 100ºF (37.8ºC) (i.e., Class 1A flammable liquids)
Materials that will spontaneously ignite when exposed to air.”
Flammables not covered by part 68 (§ 68.115)
The following flammables are not considered part of a “stationary source” and, therefore, any
regulated substances contained in them need not be included in your calculations of threshold
quantities:
• Naturally occurring hydrocarbon reservoirs; and
• Naturally occurring hydrocarbon transportation subject to oversight or regulation under a
state natural gas or hazardous liquid program for which the state has in effect a certification
to DOT under 49 U.S.C. 60105.
“Naturally occurring hydrocarbon reservoirs” includes oil and gas fields, where the hydrocar-
bons occur in nature and from which they are pumped; it does not include natural formations,
such as salt domes, where hydrocarbons are stored after they have been produced or processed.
Transportation subject to state oversight or regulation refers to transportation in pipelines.
You do not need to consider the following flammable substances when you deter-
mine the applicability of the rule:
• Gasoline, when in distribution or related storage for use as fuel for internal combustion
engines;
• Naturally occurring hydrocarbon mixtures prior to entry into a petroleum refining process
unit (NAICS code 32411) or a natural gas processing plant (NAICS code 211112). Naturally
occurring hydrocarbon mixtures include any of the following:
∆ Condensate—hydrocarbon liquid separated from natural gas that condenses because
of changes in temperature, pressure, or both, and that remains liquid at standard con-
ditions;
∆ Crude oil—any naturally occurring, unrefined petroleum liquid;
∆ Field gas—gas extracted from a production well before the gas enters a natural gas
processing plant (any processing site engaged in the extraction of natural gas liquids
from field gas, fractionation of mixed natural gas liquids to natural gas products, or
both); and
∆ Produced water—water extracted from the earth from an oil or natural gas production
well, or that is separated from oil or natural gas after extraction.

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Exclusions (§ 68.115)
The rule has a number of exclusions that allow you to ignore certain items that contain a regu-
lated substance when you determine whether a threshold quantity is present. Note that these
same exclusions apply to EPCRA section 313; you may be familiar with them if you comply with
that provision.
Articles (§ 68.115(b)(4))
You do not need to include in your threshold calculations any manufactured item defined at
§ 68.3 (as defined under 29 CFR 1910.1200(b)) that:
• Is formed to a specific shape or design during manufacture,
• Has end use functions dependent in whole or in part upon the shape or design during end
use, and
• Does not release or otherwise result in exposure to a regulated substance under normal con-
ditions of processing and use.
Uses (§ 68.115(b)(5))
You also do not need to include regulated substances in your calculation when in use for the
following purposes:
• Use as a structural component of the stationary source;
• Use of products for routine janitorial maintenance;
• Use by employees of foods, drugs, cosmetics, or other personal items containing the regu-
lated substances; and
• Use of regulated substances present in process water or non-contact cooling water as
drawn from the environment or municipal sources, or use of regulated substances present
in air used either as compressed air or as part of combustion.
Activities in Laboratories
If a regulated substance is manufactured, processed, or used in a laboratory at a stationary
source under the supervision of a technically qualified individual (as defined by § 720.3 (ee) of
40 CFR), the quantity of the substance need not be considered in determining whether a thresh-
old quantity is present. This exclusion does not extend to:
• Specialty chemical production;
• Manufacture, processing, or use of substances in pilot plant scale operations; and
• Activities conducted outside the laboratory.
1.6 Stationary Source

The rule applies to “stationary sources” and each stationary source with one or more covered
processes must file an RMP that includes all covered processes.
Simple Sources
For most facilities covered by this rule, determining what constitutes a “stationary source” is sim-
ple. If you own or lease a property, your processes are contained within the property boundary,
and no other companies operate on the property, then your stationary source is defined by the
property boundary and covers any process within the boundaries that has more than a thresh-
old quantity of a regulated substance. You must comply with the rule and file a single RMP for
all covered processes.

Annex 5
Multiple Operations Owned by a Single Company

If the property is owned or leased by your company, but several separate operating divisions of
the company have processes at the site, the divisions’ processes may be considered a single sta-
tionary source because they are controlled by a single company. Two factors will determine if
the processes are to be considered a single source: Are the processes located on one or more
contiguous properties? Are all of the operations in the same industrial group?
If your company does have multiple operations that are on the same property and are in the
same industrial group, each operating division may develop its prevention program separately
for its covered processes, but you must file a single RMP for all covered processes at the site. You
should note that this is different from the requirements for filing under CAA Title V, and EPCRA
section 313 (the annual toxic release inventory), where each division could file separately if your
company chose to do so.
Other Sources
There are situations where two or more separate companies occupy the same site. The simplest
of these cases is if multiple companies lease land at a site (e.g., an industrial park). Each com-
pany that has covered processes must file an RMP that includes information on its own covered
processes at the site. You are responsible for filing an RMP for any operations that you own or
operate.
Another possibility is that one company owns the land and operates there while leasing part of
the site to a second company. If both companies have covered processes, each is considered a
separate stationary source and must file separate RMPs even if they have contractual relation-
ships, such as supplying product to each other or sharing emergency response functions.
If you and another company jointly own a site, but have separate operations at the site, you
each must file separate RMPs for your covered processes. Ownership of the land is not relevant;
a stationary source consists of covered processes located on the same property and controlled
by a single owner.
Joint Ventures
You and another company may jointly own covered processes. In this case, the legal entity you
have established to operate these processes should file the RMP. If you consider this entity a sub-
sidiary, you should be listed as the parent company in the RMP.
Multiple Locations
If you have multiple operations in the same area, but they are not on physically connected land,
you must consider them separate stationary sources and file separate RMPs for each, even if the
sites are connected by pipelines that move chemicals among the sites. Remember, the rule
applies to covered processes at a single location.
Exhibit 1-3 provides examples of stationary source decisions.

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Exhibit 1-3
Stationary Sources
Schematic Representation Description Interpretation
same owner 1 stationary source

same industrial group 1 RMP
two owners 2 stationary sources

2 RMPs
1 ABC
1 XYZ
two owners 3 stationary sources

three industrial groups 1 ABC Chemicals
1 ABC Refinery
1 XYZ Gases
2 stationary sources
two owners 2 RMPs
Joint-Venture
same owner 1 stationary source

same industrial group 1 RMP
contiguous property
Building owned by Brown Properties
2 stationary sources
2 RMPs
two owners 1 ABC Chemicals
1 Farm Chemicals
Pet Supply Storage
(no regulated substances)

Annex 5
1.7 When You Must Comply

If you had a covered process prior to June 21, 1999, you must comply with the requirements of
part 68 no later than June 21, 1999. This means that whenever a process starts prior to June
21, 1999, you must be in compliance with the rule on June 21, 1999. You must have devel-
oped and implemented all of the elements of the rule that apply to each of your covered
processes, and you must have submitted an RMP to EPA.
If the first time you have a covered process is after June 21, 1999, or you bring a new process
on line after that date, you must comply with part 68 no later than the date on which you first
have more than a threshold quantity of a regulated substance in a process.
Qs & As
Stationary Source
Q. I operate a single covered process on a site owned by a large company. I manufac-

ture a regulated substance that I pipe to the other company for use in its processes. At
what point do the piping and substance become part of the other company’s station-
ary source?
A. The answer will vary. The company that owns and maintains the piping should probably
consider it part of its stationary source. If, however, there is a point (e.g., a valve or meter)
where the receiving company is considered to take ownership of the substance, then you
may decide to divide the piping and its contents at that point.
Q. The definition of process would seem to say that my process is part of the larger
company’s process because they are interconnected. Why can’t the larger company just
include my process in its RMP?
A. Your process is not part of the larger company’s stationary source because it does not
meet the statutory criteria for stationary sources. Although the process may be part of the
same industrial group and is at the same location, it is not under control of the same per-
son. Therefore, the process is a separate stationary source and must have a separate RMP.

Annex 5
Qs & As
Compliance Dates
Q. What happens if I bring a new covered process on line (e.g., install a second storage
tank) after June 21, 1999?
A. For a new covered process added after the initial compliance date, you must be in com-
pliance on the date you first have a regulated substance above the threshold quantity. There
is no grace period. You must develop and implement all the applicable rule elements and
update your RMP before you start operating the new process.
Q. What if EPA lists a new substance?

A. You will have three years from the date on which the new listing is effective to come
into compliance for any process that is covered because EPA has listed a new substance.
Q. What if I change a process by adding new reactor vessels, but do not change the
substances?
A. Because increasing the number of reactor vessels is a major change to your process, you
will have six months to come into compliance and update your RMP to reflect changes in
your prevention program elements and report any other changes.
Q. What if the quantity in the process fluctuates? I may not have a threshold quantity
on June 21, 1999, but I will before then and after then.
A. You do not need to comply with the rule and file an RMP until you have more than
threshold quantity in a process; however, once you have more than threshold quantity in a
process after June 21, 1999, you must be in compliance immediately. In this situation, with
fluctuating quantities, it may be prudent to file by June 21, 1999, so you will be in compli-
ance when your quantity exceeds the threshold.

Annex 5
CHAPTER 4
OFFSITE CONSEQUENCE ANALYSIS
This chapter is intended for people who plan to do their own air dispersion modeling. EPA has
prepared a separate document, Risk Management Program Guidance for Offsite Consequence
Analysis, which provides simple methods and reference tables for determining distance to an end-
point for worst-case and alternative release scenarios. In conjunction with the National
Oceanographic and Atmospheric Administration (NOAA), EPA has developed a software pro-
gram, RMP*Comp™, that performs calculations described in the Risk Management Program
Guidance for Offsite Consequence Analysis. This software is available for free from the EPA
Internet website at http://www.epa.gov/swercepp/tools/rmp-comp/rmp-comp.html. In addition,
EPA published industry guidance for several industries covered by part 68. In these documents,
EPA provides chemical-specific modeling for the covered industries. All the information provided
in this chapter is also included in EPA’s Risk Management Program Guidance for Offsite
Consequence Analysis and the industry-specific guidance documents available from EPA. If you
intend to use those guidances to carry out your offsite consequence analysis, you may skip this
chapter. If you plan to do your own modeling, this chapter will provide you with the information
you need to comply with the rule requirements; it does not provide methodologies.
4.1 Introduction
The offsite consequence analysis consists of two elements:
• A worst-case release scenario analysis applicable to all covered processes, regardless of pro-
gram level, as follows:
3
∆ To determine whether a process is eligible for Program 1, you must evaluate the worst-
case scenarios for each toxic and flammable substance held above the threshold in the
process. The process is eligible for Program 1 if there are no public receptors within the
distance to an endpoint for all of the worst-case scenarios analyzed for the process (and
the other Program 1 criteria are met—see Chapter 2). For every Program 1 process, you
must report on the worst-case scenario with the greatest distance to an endpoint.
3 3
∆ If your site has Program 2 or Program 3 processes (processes that are not eligible for
Program 1—see Chapter 2), you must analyze and report on one worst-case analysis rep-
resenting all toxic regulated substances present above the threshold quantity and one
worst-case analysis representing all flammable regulated substances present above the
threshold quantity.
∆ You may need to submit an additional worst-case analysis if a worst-case release from
elsewhere at the source would potentially affect public receptors different from those
affected by the initial worst-case scenario(s).
• An alternative release scenario analysis, applicable to all Program 2 and Program 3 processes,
as follows:
∆ Alternative release scenarios should be those that may result in concentrations, overpres-
sures, or radiant heat levels that reach the endpoints specified for these effects beyond
the fenceline of your facility.
∆ You must present information on one alternative release scenario analysis for each regu-
lated toxic substance held above the threshold quantity, including the substance consid-
ered in the worst-case analysis.
3
Refer to step 3 of Chapter 3 of this guide for the number of scenarios to present. CRAIM does not consider the notion
of program.

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∆ You must present information on one alternative release scenario analysis to represent all
flammable substances held above the threshold quantity.
If the distance to the endpoint for your worst-case release just reaches your fenceline, you may
not have an alternative release scenario with a distance to an endpoint that goes beyond the
fenceline. However, you still must report an alternative release scenario. You may want to
explain in the RMP Executive Summary why the distance does not extend beyond the fenceline.
How Should I Conduct the Analysis?

You may use EPA’s RMP Guidance Offsite Consequence Analysis to carry out your consequence
analysis. Results obtained using the methods in EPA’s Guidance are expected to be conservative.
Conservative assumptions have been introduced to compensate for high levels of uncertainty.
EPA’s guidance is optional, and you are free to use other air dispersion models, fire or explosion
models, or computation methods provided that:
• They are publicly or commercially available or are proprietary models that you are willing to
share with the implementing agency;
• They are recognized by industry as applicable to current practices;
• They are appropriate for the chemicals and conditions being modeled;
• You use the applicable definitions of worst-case scenarios; and
• You use the applicable parameters specified in the rule.
Complex models that can account for many site-specific factors may give less conservative esti-
mates of offsite consequences than the simplified methods in EPA’s guidance, particularly for
alternative scenarios, for which EPA has not specified many assumptions. However, complex
models may be expensive and require considerable expertise to use; EPA’s optional guidance is
designed to be simple and straightforward. You will need to consider the tradeoff in deciding
how to carry out your required consequence analyses. Exhibit 4-1 provides additional sugges-
tions on making this decision.
Whether you use EPA’s guidance or another modeling method, you should bear in mind that
the results you obtain from modeling your worst-case or alternative scenarios should not be con-
sidered to predict the likely results of an accidental release. The worst-case assumptions are very
conservative, and, regardless of the model used, you can expect very conservative results. Results
from modeling alternative scenarios will be less conservative; however, you still must use con-
servative endpoints.
In addition, results of an actual release will depend on many site-specific conditions (e.g., wind
speed and other weather conditions) and factors related to the release (e.g., when and how the
release occurs, how long it takes to stop it). You should make reasonable assumptions regard-
ing such factors in developing your alternative scenarios, but the circumstances surrounding an
actual release may be different. Different models likely will provide different results, even with
the same assumptions, and most models have not been verified with experimental data; there-
fore, results of even sophisticated modeling have a high degree of uncertainty and should be
viewed as providing a basis for discussion, rather than predictions. Modeling results should be
considered particularly uncertain over long distances (i.e., 10 kilometers or more).
Exhibit 4-2 provides suggestions for assistance on modeling.

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Exhibit 4-1
Considerations for Choosing a Modeling Method
Approach Examples Advantages Disadvantages
Simple guidance EPA’s Offsite • Free • Conservative results

Consequence • No computer requirements • Few site-specific factors
Analysis • Simple to use considered
Guidance • Provides all data needed • Little flexibility in scenario
• Provides tables of distances development
• Ensures compliance with rule
Simple EPA models, • No/low cost • Some may not be simple to use
computer such as • May be simple to use • Likely to give conservative results
models RMP*Comp™ • Can consider some • May not accept all of EPA’s
site-specific factors required assumptions
• May not include chemical-
specific data
• May not address all
consequences
Complex Commercially • May address a variety of • May be costly

computer available scenarios • May require high level of
models models • May consider many expertise
site-specific factors
Calculation “Yellow Book” • Low cost • May require expertise to

methods (Netherlands • No computer requirements apply methods
TNO) • May require development of a
variety of data

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Exhibit 4-2
Possible Sources of Assistance on Modeling
• You may be able to obtain modeling help from the implementing agency in your area;
for example, implementing agencies in California are preparing to provide assistance to
regulated sources.
• If you use certain models, users’ groups may be a source of assistance; for example,
there is an ALOHA model users’ group.
• If you use a commercial model, you probably can request assistance from the model
developer or distributor.
• Publications of the Center for Process Safety of the American Institute of Chemical
Engineers
∆ Guidelines for Evaluating the Characteristics of Vapor Cloud Explosions, Flash Fires,
and BLEVEs (1994);
∆ Guidelines for Uses of Vapor Cloud Dispersion Models (1987).
• EPA publications also may provide useful modeling information; examples include:
∆ Workbook of Screening Techniques for Assessing Impacts of Toxic Air Pollutants,
EPA-450/4-88-009 (September 1988);
∆ Guidance on the Application of Refined Dispersion Models for Hazardous/Toxic Air
Release, EPA-454/R-93-002 (May 1993);
∆ EPA guidance is available at http://www.epa.gov/scram001//.

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4.2 Worst-case Release Scenarios

EPA has defined a worst-case release as the release of the largest quantity of a regulated sub-
stance that results in the greatest distance from the point of release to a specified endpoint
(§68.3). You must estimate the distance as follows:
• Part 68, Appendix A lists the toxic endpoint you must use for each regulated toxic substance.
For the worst-case analysis for toxic substances, you are required to estimate the air dispersion
distance to the endpoint, using certain conservative assumptions concerning quantity released
and release conditions.
• A vapor cloud explosion is specified as the worst-case scenario for flammable substances. For
the worst-case analysis for flammable substances, you need to estimate the distance to an
overpressure endpoint of 1 pound per square inch (psi) resulting from a vapor cloud explosion
of a cloud containing the largest quantity of the regulated flammable substance from a ves-
sel or process pipeline failure.
This section describes the assumptions you must make and what you need to do to meet the
requirements for worst-case scenario analysis under the rule. Exhibit 4-3 summarizes the
required parameters for the worst-case analysis.
Worst-case Releases of Toxic Substances

For the worst-case release analysis for toxic substances, you need to use the assumptions dis-
cussed below, the properties of the substance, and an appropriate air dispersion model or EPA’s
optional guidance to estimate the distance from the release point to the point at which the con-
centration of the substance in air is equal to the toxic endpoint specified in the rule. Because the
assumptions required for the worst-case analysis are very conservative, the results likely will be
very conservative. The endpoints specified for the regulated toxic substances are intended to be
protective of the general public. These endpoints are concentrations below which it is believed
nearly all individuals could be exposed for one-half to one hour without any serious health
effects. In addition, the worst-case analysis is carried out using very conservative assumptions
about weather and release conditions. The distance to the endpoint estimated under worst-case
conditions should not be considered a zone in which the public would likely be in danger;
instead, it is intended to provide an estimate of the maximum possible area that might be affect-
ed in the unlikely event of catastrophic conditions. Distances greater than about 10 kilometers
are particularly uncertain. EPA intends the estimated distances to provide a basis for a discussion
among the regulated community, emergency responders, and the public, rather than a basis for
any specific actions.
Modeling Assumptions
Quantity. EPA has defined (§68.3) a worst-case release as the release of the largest quantity of
a regulated substance from a vessel or process line failure that results in the greatest distance to
a specified endpoint. For substances in vessels, you must assume release of the largest amount
in a single vessel; for substances in pipes, you must assume release of the largest amount in a
pipe.
The largest quantity should be determined taking into account administrative controls.
Administrative controls are written procedures that limit the quantity of a substance that can be
stored or processed in a vessel or pipe at any one time, or, alternatively, occasionally allow a ves-
sel or pipe to store larger than usual quantities (e.g., during turnaround). You do not need to
consider the possible causes of the worst-case release or the probability that such a release
might occur; the release is simply assumed to take place.

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Exhibit 4-3
Required Parameters for Modeling Worst-case Scenarios
Endpoints
• For toxic substances, use the endpoint specified in part 68, Appendix A.
• For flammable substances, use the endpoint of an overpressure of 1 pound per square
inch (psi) for vapor cloud explosions.
Wind speed/stability
• Use wind speed of 1.5 meters per second and F stability class unless you can demon-
strate that local meteorological data applicable to the site show a higher minimum wind
speed or less stable atmosphere at all times during the previous three years. If you can
demonstrate a higher minimum wind speed or less stable atmosphere over three years,
these minimums may be used.
Ambient temperature/humidity
• For toxic substances, use the highest daily maximum temperature during the past three
years and average humidity for the site.
Height of release
• For toxic substances, assume a ground level release.
Topography
• Use urban or rural topography, as appropriate.
Dense or neutrally buoyant gases
• Tables or models used for dispersion of regulated toxic substances must appropriately
account for gas density.
Temperature of released substance
• For liquids (other than gases liquefied by refrigeration), use the highest daily maximum
temperature, based on data for the previous three years, or at process temperature,
whichever is higher.
• Assume gases liquefied by refrigeration at atmospheric pressure are released at their
boiling points.

Annex 5
Release Height. All releases are assumed to take place at ground level for the worst-case analy-
sis. This is a conservative assumption in most cases. Even if you think a ground-level release is
unlikely at your site, you must use this assumption for the worst-case analysis.
Wind Speed and Atmospheric Stability. Meteorological conditions for the worst-case scenario
are defined in the rule as atmospheric stability class F (stable atmosphere) and wind speed of
1.5 meters per second (3.4 miles per hour). If, however, you can demonstrate that the minimum
wind speed at your site (measured at 10 meters) has been higher than 1.5 meters per second,
or that the maximum atmosphere stability has always been less stable than class F, you may use
the minimum wind speed and most stable atmospheric conditions at your site for the worst-
case analysis. To demonstrate higher minimum wind speeds or less stable atmospheric condi-
tions, you will need to document local meteorological data from the previous three years that
are applicable to your site. If you do not keep weather data for your site (most sources do not),
you may call another nearby source, such as an airport, or a compiler, such as the National
Weather Service, to determine wind speeds for your area. Exhibit 3-1 in Chapter 3 describes
atmospheric stability classes in relation to wind speed and cloud cover. Your airport or other
source will be able to give you information on cloud cover. A small difference in wind speed
probably will not lead to a significant decrease in the distance to the endpoint.
Temperature and Humidity. For the worst-case release of a regulated toxic substance, you must
assume the highest daily maximum temperature that occurred in the previous three years (the
highest temperature reached in the last three years) and the average humidity for the site. If you
have not kept information on temperature and humidity at your site, you may obtain it from a
local meteorological station. EPA’s RMP Guidance for Offsite Consequence Analysis assumes a
temperature of 25ºC (77ºF) and 50 percent humidity. If you use the EPA’s guidance for your off-
site consequence analysis, you may use these assumptions even if the actual highest tempera-
ture at your site is higher or lower. If the temperature at your site is significantly lower, EPA’s guid-
ance may give overly conservative results, particularly for toxic liquids. Small differences in tem-
perature and humidity are unlikely to have a major effect on results, however.
Topography. Two choices are provided for topography for the worst-case scenario. If your site
is located in an area with few buildings or other obstructions, you should assume open (rural)
conditions. If your site is in an urban location, or is in an area with many obstructions, you should
assume urban conditions.
Gas or Vapor Density. For the worst-case analysis, you must use a model appropriate for the
density of the released gas or vapor. Generally, for a substance that is lighter than air or has a
density similar to that of air, you would use a model for neutrally buoyant vapors. The initial
vapor density of a substance with respect to air can be estimated from its molecular weight,
assuming air has a “molecular weight” of approximately 29. For a substance that is heavier than
air (molecular weight greater than 29), you generally would use a dense gas model. There are
cases where a dense gas model may be appropriate for a substance with molecular weight of
29 or less (e.g., release of a compressed gas as a cold vapor) or where a neutrally buoyant plume
model may be appropriate for a substance with a higher molecular weight (e.g., release by slow
evaporation, with considerable mixing with air). In addition, dense gases and vapors will become
neutrally buoyant through mixing with air as they move downwind. If you can account for such
conditions in modeling, you may do so.

Annex 5
Estimating Release Rates

Toxic Gases. Toxic gases include all regulated toxic substances that are gases at ambient tempera-
ture (temperature 25ºC, 77ºF). For the consequence analysis, the total quantity in the single largest
vessel or process line is assumed to be released as a gas over a period of 10 minutes, except in the
case of gases liquefied by refrigeration under atmospheric pressure. The release rate (per minute)
for a gas (not liquefied by refrigeration) is the total quantity released divided by 10. Passive mitiga-
tion measures (e.g., enclosure) may be taken into account in the analysis of the worst-case sce-
nario. A 10-minute release must be assumed for gases regardless of the model you use.
Gases liquefied by refrigeration alone (not under pressure) and released into diked areas may be
modeled as liquids at their boiling points, if the pool formed by the released liquid would be greater
than one centimeter (0.39 inches) in depth. In this case, you may assume the liquefied gas is
released from a pool by evaporation at the boiling point of the gas. If the refrigerated liquefied gas
is not contained by passive mitigation, or if the pool formed would have a depth of one centime-
ter or less, you must treat the released substance as a gas released over 10 minutes. EPA’s analysis
indicated that pools of gas liquefied by refrigeration with a depth of one centimeter or less would
evaporate so rapidly at their boiling points that treatment as gaseous releases over 10 minutes is
reasonable.
Toxic Liquids. For toxic liquids, you must assume that the total quantity in a vessel is spilled,
forming a pool. For toxic liquids carried in pipelines, you must assume that the largest quantity
that might be released from the pipeline forms a pool. Passive mitigation systems (e.g., dikes)
may be taken into account in consequence analysis. You must assume that the total quantity
spilled spreads instantaneously to a depth of one centimeter (0.39 inches) in an undiked area or
covers a diked area instantaneously. You estimate the release rate to air as the rate of evapora-
tion from the pool. To estimate the evaporation rate, you need to estimate the surface area of
the pool. You can take into account the surface characteristics of the area into which the liquid
would be spilled; for example, some models for pool evaporation will take into account the type
of soil if the spill will take place in an unpaved area. Your modeling also should consider the
length of time it will take for the pool to evaporate.
You may use any appropriate model to estimate the evaporation rate of a spilled regulated substance
from a pool and estimate the air dispersion distance to the specified endpoint of the regulated sub-
stance. The release rate can then be used to estimate the distance to the endpoint.
Estimating Distance to the Endpoint
You may use any appropriate model, as discussed above, to estimate the distance to the end-
point specified in part 68 Appendix A for a release of a regulated toxic substance, using the
required modeling assumptions.
Worst-case Releases of Flammable Substances

For the worst-case scenario involving a release of a regulated flammable substance (a flamma-
ble gas or volatile flammable liquid), you must assume that the quantity of the flammable sub-
stance is released into a vapor cloud and that a vapor cloud explosion results. You must estimate
the distance to an endpoint to an overpressure level of 1 pound per square inch (psi) from the
explosion of the vapor cloud.

Annex 5
• If the flammable substance is normally a gas at ambient temperature and handled as gas or
liquid under pressure or if the flammable substance is a gas handled as a refrigerated liquid
and is not contained when released or the contained pool is one centimeter or less deep, you
must assume the total quantity is released as a gas and is involved in a vapor cloud explosion.
• If the flammable substance is a liquid or a refrigerated gas released into a containment area
with a depth greater than one centimeter, you may assume that the quantity that volatilizes
in 10 minutes is involved in a vapor cloud explosion.
As in the case of the worst-case release analysis for toxic substances, the worst-case distance to
the endpoint for flammable substances is based on a number of very conservative assumptions.
Release of the total quantity of a flammable substance in a vessel or pipe into a vapor cloud
generally would be highly unlikely. Vapor cloud explosions are also unlikely events; in an actual
release, the flammable gas or vapor released to air might disperse without ignition, or it might
burn instead of exploding, with more limited consequences. The endpoint of 1 psi is intended
to be conservative and protective; it does not define a level at which severe injuries or death
would be commonly expected. An overpressure of 1 psi is unlikely to have serious direct effects
on people; this overpressure may cause property damage such as partial demolition of houses,
which can result in injuries to people, and shattering of glass windows, which may cause skin
laceration from flying glass.
To carry out the worst-case consequence analysis for flammable substances, you may use a TNT-
equivalent model (i.e., a model that estimates the explosive effects of a flammable substance by
comparison with the effects of an equivalent quantity of the high explosive trinitrotoluene (TNT),
based on the available combustion energy in the vapor cloud). Such models allow you to esti-
mate the distance to a specific overpressure level, based on empirical data from TNT explosions.
If you use a TNT-equivalent model, you must assume that 10 percent of the flammable vapor in
the cloud participates in the explosion (i.e., you assume a 10 percent yield factor for the explo-
sion). You do not have to use a TNT-equivalent model; other available models take into account
more site-specific factors (e.g., degree of confinement of the vapor cloud). Generally, however,
a TNT-equivalent model is the simplest to use.
4
Number of Scenarios
The number of worst-case scenarios you must analyze depends on several factors as discussed
below. You only need to consider the hazard (toxicity or flammability) for which a substance is
regulated (i.e., even if a regulated toxic substance is also flammable, you only need to consider
toxicity in your analysis; even if a regulated flammable substance is also toxic, you only need to
consider flammability).
Program 1 Processes
To demonstrate that a process is eligible for Program 1 (see Chapter 2), you conduct a worst-
case release analysis of it and that analysis must show that the distance to the specified end-
point for every regulated substance in the process is smaller than the distance to any public
receptor. If you have several processes that may qualify for Program 1, you will have to carry out
a worst-case analysis for each process to determine which qualify. You will need to report in the
RMP the worst-case results for those processes you determine to be eligible for Program 1.
4
of program.

Annex 5
If the distance to the endpoint in the worst-case analysis is equal to or greater than the distance
to any public receptor, the process would be in Program 2 or Program 3 (discussed below).
When you consider possible eligibility of your processes for Program 1, you may want to look
particularly at processes containing flammable substances, which are likely to give shorter worst-
case distances than toxic substances.
Program 2 and 3 Processes
For all your Program 2 and 3 processes together (see Chapter 2), you must carry out and report
in the RMP one worst-case analysis for the regulated toxic substances and one worst-case analy-
sis for the regulated flammable substances held above their threshold quantities. The basic pur-
pose of the worst-case analysis is to identify all of the public receptors that could be affected by
a worst-case release. The release that results in the greatest distance to an endpoint would affect
the greatest number of public receptors so only that release (and not others affecting a subset
of those receptors) needs to be reported. The reported scenario for toxic substances must be
the scenario estimated to result in the greatest distance to a specified toxic endpoint; for flam-
mable substances, it must be the scenario estimated to lead to the greatest distance to 1 psi
overpressure for a vapor cloud explosion. Additional worst-case analyses must be reported for
toxic or flammable substances if a worst-case release from a different location at the facility
potentially would affect different public receptors from those affected by the scenario giving the
greatest distance.
Identifying the “Worst” Worst-case Scenario

Toxics
To determine the scenario that gives the greatest distance to an endpoint for processes contain-
ing toxic substances, you may have to analyze more than one scenario, because the distances
depend on more than simply the quantity in a process. For toxic liquids, for example, distances
depend on the magnitude of the toxic endpoint, the molecular weight and volatility of the sub-
stance, and the temperature of the substance in the process, as well as quantity. A smaller quan-
tity of a substance at an elevated temperature may give a greater distance to the endpoint than
a larger quantity of the same substance at ambient temperature. In some cases, it may be dif-
ficult to predict which substance and process will give the greatest worst-case distance. You also
may need to carry out analyses of worst-case scenarios for locations at significant distances from
each other to determine whether different public receptors might be affected by releases.
Flammables
For flammable substances, the greatest quantity in a process is likely to give the greatest distance
to the endpoint, but there may be variations, depending on heat of combustion and distance to
the fenceline. You may have to carry out several analyses to identify the scenario that gives the
greatest distance to the endpoint. As in the case of toxic substances, you also may need to carry
out analyses for locations far apart from each other to determine whether different public recep-
tors might be affected.
For both toxic and flammable substances, the worst-case distances should be considered only
approximations.

Annex 5
Qs & As
Worst-case and Mitigation
Q. At my facility, if the worst-case release scenarios for regulated toxic substances and
the worst-case scenario for regulated flammable substances involve the same process,
must I analyze both?
A. Yes. If the worst-case release scenarios for regulated toxic substances and regulated
flammable substances in Program 2 and 3 processes are associated with the same process,
the two worst-case release scenarios must be analyzed separately.
Q. What measures qualify as “passive mitigation”?

A. Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that func-
tion without human, mechanical, or other energy input.” Passive mitigation systems
include building enclosures, dikes, and containment walls. Measures such as fire sprinkler
systems, water curtains, valves, scrubbers, or flares would not be considered passive miti-
gation because they require human, mechanical, or energy input to function.
Q. When analyzing the worst-case scenario for regulated toxic substances, must I antic-
ipate a specific cause (e.g., fire, explosion, etc.) of the scenario?
A. No. The worst-case analysis for a release of regulated toxic substances must conform to
specific assumptions as identified in § 68.25(c) and (d). Anticipated causes of the release
will not affect the analysis, and are not required. A specific cause may be considered in ana-
lyzing the alternative release scenarios although it is not a requirement.
Q. Would all of the regulated substances stored in a salt dome be assumed to be

released in the worst-case scenario?
A. The worst-case scenario for salt domes would be examined in a manner similar to that
for underground storage tanks. Reservoirs or vessels sufficiently buried underground are
passively mitigated or prevented from failing catastrophically. You should evaluate the fail-
ure of piping connected to underground storage for the worst-case and alternative scenar-
ios.
Q. Are valves in piping considered administrative controls?

A. No, administrative controls are written procedures that limit the quantity stored or flow-
ing through the pipes. Valves are considered active mitigation systems.

Annex 5
4.3 Alternative Release Scenarios

There are only a few required assumptions for the alternative scenario analysis.
Exhibit 4-4 summarizes the required assumptions.
Exhibit 4-4
Required Parameters for Modeling Alternative Scenarios
Endpoints
• For toxic substances, use the endpoints specified in part 68, Appendix A.
• For flammable substances, use as the endpoints:
∆ Overpressure of 1 pound per square inch (psi) for vapor cloud explosions,
∆ Radiant heat of 5 kilowatts per square meter (kW/m2) (or equivalent dose) for fireballs or pool
fires, or
∆ Lower flammability limit (LFL) for vapor cloud fires.
5
Wind speed/stability
• Use typical meteorological conditions at your site.
Ambient temperature/humidity
• Use average temperature/humidity data gathered at your site or at a local meteorological
station.
Height of release
• Release height may be determined by the release scenario.
Topography
• Use urban or rural topography, as appropriate.
Dense or neutrally buoyant gases
• Tables or models used for dispersion of regulated toxic substances must appropriately
account for gas density.
Temperature of released substance
• Substances may be considered to be released at a process or ambient temperature that
is appropriate for the scenario.
5
CRAIM recommends the use of the worst meteorological conditions for alternative release scenarios.

Annex 5
Acceptable Alternative Scenarios

Your alternative scenario for a covered process must be one that is more likely to occur than the
worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. You do
not need to demonstrate greater likelihood of occurrence or carry out any analysis of probabil-
ity of occurrence; you only need to use reasonable judgement and knowledge of the process.
If, using a combination of reasonable assumptions, modeling of a release of a regulated sub-
stance from a process shows that the relevant endpoint is not reached offsite, you can use the
modeling results to demonstrate that a scenario does not exist for the process that will give an
endpoint offsite. You must report an alternative scenario, however.
Release scenarios you should consider include, but are not limited to, the following,
where applicable:
• Transfer hose releases due to splits or sudden uncoupling;
• Process piping releases from failures at flanges, joints, welds, valves and valve seals, and
drains or bleeds;
• Process vessel or pump releases due to cracks, seal failure, drain bleed, or plug failure;
• Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture
disks; and
• Shipping container mishandling and breakage or puncturing leading to a spill.
For alternative release scenarios, you may consider active mitigation systems, such as interlocks,
shutdown systems, pressure relieving devices, flares, emergency isolation systems, and fire water
and deluge systems, as well as passive mitigation systems. Mitigation systems considered must
be capable of withstanding the event that triggers the release while remaining functional.
You must consider your five-year accident history and failure scenarios identified in your hazard
review or process hazards analysis in selecting alternative release scenarios for regulated toxic or
flammable substances (e.g., you might choose an actual event from your accident history as the
basis of your scenario). You also may consider any other reasonable scenarios.
The alternative scenarios you choose to analyze should be scenarios that you consider possible
at your site. Although EPA requires no explanation of your choice of scenario, you should choose
a scenario that you think you can explain to emergency responders and the public as a reason-
able alternative to the worst-case scenario. For example, you could pick a scenario based on an
actual event, or you could choose a scenario that you worry about, because circumstances at
your site might make it a possibility. If you believe that there is no reasonable scenario that could
lead to offsite consequences, you may use a scenario that has no offsite impacts for your alter-
native analysis. You should be prepared to explain your choice of such a scenario to the public,
should questions arise.

Annex 5
Alternative Releases of Toxic Substances

To estimate distances to the endpoint for alternative releases of toxic substances, you need to
identify reasonable scenarios for the regulated substances in covered processes at your site and
model these scenarios using appropriate models. As noted above, for alternative release scenar-
ios, you are permitted to take credit for both passive and active mitigation systems, or a combi-
nation if both are in place. Modeling alternative releases of toxic substances is discussed below.
Although alternative scenarios are intended to be more likely than worst-case scenarios, the
analysis of alternative scenarios should not be expected to provide realistic estimates of areas in
which the public might be endangered in case of a release. The same conservative, protective
endpoints are used for alternative release analysis as for worst-case analysis. These endpoints are
intended to represent exposure levels below which most members of the public will not suffer
any serious health effects. The endpoints are based on exposures for longer periods than may
be likely in an actual release. In addition, modeling carried out to estimate distances to these
endpoints, even when based on more realistic assumptions than used for the worst-case mod-
eling, likely will provide results with a high degree of uncertainty. These estimated distances
should not be considered a necessarily accurate prediction of the results of an actual release.
Quantity. EPA has not specified any assumptions you must make concerning quantity released
for an alternative release scenario. You could consider any site-specific factors in developing a
reasonable estimate of quantity released (e.g., the quantity that could be released from a
sheared pipe in the time it would take to shut off flow to the pipe).
Release Height. You may assume any appropriate release height for your alternative scenarios.
For example, you may analyze a scenario in which a regulated substance would be released at
a height well above ground level.
Wind Speed and Atmospheric Stability. You should use typical meteorological conditions at
your site to model alternative scenarios. To determine typical conditions, you may need to obtain
local meteorological data that are applicable to your site. If you do not keep weather data for
your site (most sources do not), you may call another nearby source, such as an airport, or a
compiler, such as the National Weather Service, to determine wind speeds6 for your area. Your
airport or other source will be able to give you information on cloud cover.
6
In Canada, the best source is Environment Canada.

Annex 5

Toxic Gases. To estimate a release rate for toxic gases, you may make any appropriate assumptions
based on conditions at your site and use any appropriate model. EPA’s RMP Guidance for Offsite
Consequence Analysis provides a simple equation and chemical-specific data for estimating the
release rate of a gas from a hole in a vessel or pipe based on hole size, tank pressure, and chemi-
cal properties. The size of the hole might be estimated from, for example, the hole size that would
result from shearing off a valve or pipe from a vessel.
Tank or pipe damage or failure resulting in the release of a gas liquefied under pressure might
be an appropriate alternative scenario at some sites. If such a release would be possible at your
site, you may need to consider a model or method that will deal with this type of scenario.
You also should consider the duration of the release. EPA does not require you to assume any
specific time period for the release. You could estimate the release duration based on the length
of time it would take to stop the release, or you could estimate a maximum duration based on
a calculated release rate and the quantity in the tank or pipes. If you estimate that a release of
toxic gas would be stopped very quickly, resulting in a “puff” rather than a plume, you may
want to use a model that deals with puff releases. EPA’s RMP Guidance for Offsite Consequence
Analysis is not appropriate for estimating distance to an endpoint for puff releases.
You may consider both passive and active mitigation in estimating release rates. For gases, pas-
sive mitigation may include enclosed spaces. Active mitigation for gases may include an assort-
ment of techniques including automatic shutoff valves, rapid transfer systems (emergency dein-
ventory), and water/chemical sprays. These mitigation techniques have the effect of reducing
either the release rate or the duration of the release, or both. EPA’s RMP Guidance for Offsite
Consequence Analysis includes methods of accounting for mitigation. You also may use your
knowledge or other methods to account for mitigation.
Toxic Liquids. For alternative releases of toxic liquids, you may consider any scenario that would
be reasonable for your site. For alternative release scenarios, you are permitted to take credit for
both passive and active mitigation systems, or a combination if both are in place. For liquids,
passive mitigation may include techniques such as dikes and trenches. Active mitigation for liq-
uids may include an assortment of techniques including automatic shutoff valves, emergency
deinventory, foam or tarp coverings, and water or chemical sprays. These mitigation techniques
have the effect of reducing either the quantity released into the pool or the evaporation rate
from the pool. EPA’s RMP Guidance for Offsite Consequence Analysis discusses some methods
of accounting for mitigation.

Annex 5

For worst-case releases, you may use any appropriate model (as discussed in 4.1) to estimate the
distance to the specified endpoint for an alternative release of a regulated toxic substance. You
may use site-specific conditions, including typical weather conditions, and consider any site-spe-
cific factors appropriate to your scenario. You must use the endpoints specified in part 68
Appendix A, as for the worst-case analysis.
Alternative Releases of Flammable Substances

Alternative release scenarios for flammable substances are somewhat more complicated than
for toxic substances because the consequences of a release and the endpoint of concern may
vary. For the worst case, the consequence of concern is a vapor cloud explosion, with an over-
pressure endpoint. For alternative scenarios involving fires rather than explosions, other end-
points than overpressure (e.g., heat radiation) may need to be considered. The rule specifies
endpoints for fires based on the heat radiation level that may cause second degree burns from
a 40-second exposure and the lower flammability limit (LFL), which is the lowest concentration
in air at which a substance will burn. Some possible scenarios involving flammable substances
are discussed below.
• Vapor cloud fire. Vapor cloud fires (flash fires) may result from dispersion of a cloud of flam-
mable vapor and ignition of the cloud following dispersion. Such a fire could flash back and
could represent a severe heat radiation hazard to anyone in the area of the cloud. Vapor cloud
fires may be modeled using air dispersion modeling techniques to estimate distances to a con-
centration equal to the LFL.
• Pool fire. A pool fire, with potential radiant heat effects, may result from a spill of a flamma-
ble liquid. The endpoint for this type of fire, as listed in the rule, is a radiant heat level of 5 kilo-
watts per square meter (kW/m2) for 40 seconds; a 40-second exposure to this heat level could
cause second degree burns.
• Boiling liquid, expanding vapor explosion (BLEVE). A boiling liquid, expanding vapor
explosion (BLEVE), leading to a fireball that may produce intense heat, may occur if a vessel
containing flammable material ruptures explosively as a result of exposure to fire. Heat radia-
tion from the fireball is the primary hazard; vessel fragments and overpressure from the explo-
sion also can result. BLEVEs are generally considered unlikely events. However, if you think a
BLEVE is possible at your site, you should estimate the distance at which radiant heat effects
might cause second degree burns, since that is the effect of concern underlying the rule’s end-
point for fires. The point of offsite consequence analyses is to determine how far away from
the point of release effects of concern could occur, so you should estimate the distance for
BLEVEs even if they do not last for 40 seconds. For short-duration BLEVEs, you would need to
estimate the radiant heat level at which exposure for the duration of the BLEVE would cause
second degree burns. You then would need to estimate the distance to that heat level. You
also may want to consider models or calculation methods to estimate effects of vessel frag-
mentation, although you are not required to analyze such effects.

Annex 5
• Vapor cloud explosion. For a vapor cloud explosion to occur, rapid release of a large quan-
tity of flammable material, turbulent conditions (caused by a turbulent release or congested
conditions in the area of the release, or both), and other factors are generally necessary. Vapor
cloud explosions generally are considered unlikely events; however, if conditions at your site
are conducive to vapor cloud explosions, you may want to consider a vapor cloud explosion
as an alternative scenario. The 1 psi overpressure endpoint still applies to a vapor cloud explo-
sion for purposes of analyzing an alternative scenario, but you could use less conservative
assumptions than for the worst-case analysis, including any reasonable estimate of the quan-
tity in the cloud and the yield factor. A vapor cloud deflagration, involving lower flame speeds
than a detonation and resulting in less damaging blast effects, is more likely than a detona-
tion. You may assume a vapor cloud deflagration for the alternative scenario, if you think it is
appropriate, and use the radiant heat endpoint (adjusted for duration).
• Jet fire. A jet fire may result from the puncture or rupture of a tank or pipeline containing a
compressed or liquefied gas under pressure. The gas discharging from the hole can form a jet
that “blows” into the air in the direction of the hole; the jet then may ignite. Jet fires could
contribute to BLEVEs and fireballs if they impinge on tanks of flammable substances. A large
horizontal jet fire may have the potential to pose an offsite hazard. You may want to consid-
er a jet fire as an alternative scenario, if appropriate for your site.
Quantity. EPA has not specified any assumptions you must make concerning quantity released
for alternative scenario analysis for flammable substances. You may consider any site-specific fac-
tors in developing a reasonable estimate of quantity released, as for toxic substances (e.g., the
quantity that could be released from a ruptured pipe in the time it would take to shut off flow
to the pipe).
Release Height. You may assume any appropriate release height for your alternative scenarios
for flammable substances.
7
Wind Speed and Atmospheric Stability. Meteorological conditions may have little effect on
some scenarios for flammable substances (e.g., vapor cloud explosions and BLEVEs), but may
have a relatively large effect on others (e.g., a vapor cloud fire resulting from downwind disper-
sion of a vapor cloud and subsequent ignition). You should use typical meteorological conditions
at your site to model appropriate alternative scenarios. To determine typical conditions, you may
need to obtain local meteorological data that are applicable to your site, as discussed above.
7
CRAIM recommends the use of the worst meteorological conditions for alternative release scenarios.

Annex 5

Flammable Gases. To estimate a release rate for flammable gases, you may make any appropri-
ate assumptions based on conditions at your site. You may consider the effects of both passive
and active mitigation systems. The methods provided in EPA’s RMP Guidance for Offsite
Consequence Analysis for rate of release of a gas from a hole in a vessel or pipe for toxic gases
also can be used for flammable gases. Chemical-specific data are provided for flammable gases,
to be used along with hole size and tank pressure to estimate release rates.
Flammable Liquids. For alternative releases of flammable liquids, you may consider any scenario
that would be reasonable for your site. You are permitted to take credit for both passive and
active mitigation systems, or a combination if both are in place, as for toxic liquids. You could
consider release of the liquid into a pool and release to air by pool evaporation, if you consider
this to be a reasonable scenario.
If evaporation of a flammable liquid from a pool is an appropriate assumption for your alterna-
tive scenario, you can use any scientifically appropriate method to estimate the evaporation rate.
You may use any appropriate model to estimate the distance to the specified endpoint for alter-
native scenarios for regulated flammable substances. Several possible consequences of releases
of flammable substances are discussed below.
Vapor Cloud Fire. You may use any appropriate model to estimate distances for a vapor cloud
fire. The LFL endpoint, specified in the rule, would be appropriate for vapor cloud fires. You may
use air dispersion modeling to estimate the maximum distance to the LFL. You may want to con-
sider, however, whether it is likely that a flammable gas or vapor could disperse to the maximum
distance to the LFL before reaching an ignition source. The actual dispersion distance before igni-
tion might be much shorter than the maximum possible distance.
Pool Fire. Any appropriate model may be used for pool fires of flammable liquids. The applica-
ble endpoint specified in the rule is the heat radiation level of 5 kW/m2.
BLEVE. If a fireball from a BLEVE is a potential release scenario at your site, you may use any
model or calculation method to estimate the distance to a radiant heat level that can cause sec-
ond degree burns (a heat “dose” equivalent to the specified radiant heat endpoint of 5 kW/m2
for 40 seconds).
Vapor Cloud Explosion. If you have the potential at your site for the rapid release of a large
quantity of a flammable vapor, particularly into a congested area, a vapor cloud explosion may
be an appropriate alternative release scenario. For the alternative analysis, you may estimate any
reasonable quantity of flammable substance in the vapor cloud. The endpoint for vapor cloud
explosions is 1 psi, as for the worst case; however, a smaller yield factor may be used for the
alternative scenario analysis.

Annex 5
8
Number of Scenarios
You are required to analyze at least one alternative release scenario for each listed toxic sub-
stance you have in a Program 2 or Program 3 process above its threshold quantity. Even if you
have a substance above the threshold in several processes or locations, you need only analyze
one alternative scenario for it. You also are required to analyze one alternative release scenario
representing all regulated flammable substances in Program 2 or 3 processes; you do not need
to analyze an alternative scenario for each flammable substance above the threshold. For exam-
ple, if you have five listed substances—chlorine, ammonia, hydrogen chloride, propane, and
acetylene— above the threshold in Program 2 or 3 processes, you will need to analyze one alter-
native scenario each for chlorine, ammonia, and hydrogen chloride (toxics) and a single alterna-
tive scenario to cover propane and acetylene (flammable substances).
No alternative scenario analysis is required for regulated substances in Program 1 processes. If
the worst-case analysis shows no public receptors within the distance to the endpoint, and the
process meets the other Program 1 criteria, you do not have to carry out an alternative scenario
analysis.
In addition, no alternative scenario analysis is required for any process that does not contain
more than a threshold quantity of a regulated substance, even if you believe such a process is
a likely source of a release.
4.4 Estimating Offsite Receptors
The rule requires that you estimate in the RMP residential populations within the circle defined
by the endpoint for your worst-case and alternative release scenarios (i.e., the center of the cir-
cle is the point of release and the radius is the distance to the endpoint). In addition, you must
report in the RMP whether certain types of public receptors and environmental receptors are
within the circles.
Residential Populations
To estimate residential populations, you may use the most recent Census data or any other
source of data that you believe is more accurate. You are not required to update Census data
or conduct any surveys to develop your estimates. Census data are available in public libraries
and in the LandView system, which is available on CD-ROM. The rule requires that you estimate
populations to two significant digits. For example, if there are 1,260 people within the circle,
you may report 1,300 people. If the number of people is between 10 and 100, estimate to the
nearest 10. If the number of people is less than 10, provide the actual number.
Census data are presented by Census tract. If your circle covers only a portion of the tract, you
should develop an estimate for that portion. The easiest way to do this is to determine the pop-
ulation density per square mile (total population of the Census tract divided by the number of
square miles in the tract) and apply that density figure to the number of square miles within your
circle. Because there is likely to be considerable variation in actual densities within a Census tract,
this number will be approximate. The rule, however, does not require you to correct the num-
ber.
8
of program.

Annex 5
Other Public Receptors

Other public receptors must be noted in the RMP (see the discussion of public receptors in
Chapter 2). If there are any schools, residences, hospitals, prisons, public recreational areas or
arenas, or commercial or industrial areas within the circle, you must report that. You are not
required to develop a list of all public receptors; you must simply check off that one or more
such areas is within the circle. Most receptors can be identified from local street maps.
Environmental Receptors
Environmental receptors are defined as natural areas such as national or state parks, forests, or
monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and federal
wilderness areas. Only environmental receptors that can be identified on local U.S. Geological
Survey (USGS) maps need to be considered. You are not required to locate each of these specif-
ically. You are only required to check off in the RMP which specific types of areas are within the
circle. If any part of one of these receptors is within your circle, you must note that in the RMP.
Important: The rule does not require you to assess the likelihood, type, or severity of potential
impacts on either public or environmental receptors. Identifying them as within the circle simply
indicates that they could be adversely affected by the release.
Qs & As
Offsite Consequence Analysis
Q. How close must a stationary source be to a weather station for that station’s data to
be applicable to the stationary source?
A. EPA has not set specific distance limits, but will allow owners and operators to use rea-
sonable judgement in determining whether data from a weather station is applicable to the
stationary source. Factors such as topography and distance between the stationary source
and a weather station should be taken into consideration when evaluating the applicabili-
ty of the weather station’s data to the stationary source.
Q. Must air dispersion models that are used to analyze worst-case release scenarios be
able to account for multiple vessels and how those vessels could impact one another in
the event of an accidental release?
A. No. Models used for worst-case release scenario analysis do not need to consider com-
pounding effects of accidental releases from multiple vessels because worst-case release is
defined by the rule as a single vessel or process line failure that will result in the greatest dis-
tance to an endpoint.
Q. If the estimated population changes, would the RMP have to be updated?

A. No. Changes in U.S. Census data do not necessitate the revision of the RMP. However,
all updates to the RMP should use the most recent U.S. Census data.

Annex 5
Q. What if a flammable event has a different time duration than the 5 KW/m2 for 40
seconds?
A. EPA recognizes that flammable events may occur for a different amount of exposure
time. Therefore, the owner or operator should determine the distance to an equivalent
exposure—e.g., if the flammable event occurs for 20 seconds, what is the distance to an
equivalent exposure (XX KW/m2)?
Q. Could positive buoyancy models be used?

A. Yes, provided there is a basis for use and the owner or operator explains the rationale
for use of positive buoyancy models.

Annex 5
4.5 Examples of Worst Case
Example—Source A
Source A, a retail operation that supplies ammonia and propane, has one covered process: a
200-ton ammonia storage tank. Source A carries out worst-case consequence analyses for this
process, with the following results: For 400,000 pounds of anhydrous ammonia, the distance
to the specified endpoint (0.14 mg/L) is estimated as more than 10 miles.
Residences and a business center are located within 0.15 miles of the facility; therefore, the reg-
ulated process is not eligible for Program 1. Source A must report the results of the worst-case
analysis in the RMP.
Example—Source B
Source B is a medium-sized metal products manufacturer with two processes containing regu-
lated toxic substances above their thresholds: a tank storing 50,000 pounds of 37 percent
hydrochloric acid for use in plating processes and five interconnected, one-ton tanks of chlorine
used in a wastewater treatment plant. Only one worst-case analysis is required for toxic sub-
stances for Program 2 and Program 3 processes; because of the greater toxicity and volatility of
chlorine, Source B expects that a worst-case release of chlorine would result in the greatest dis-
tance to the endpoint. Source B does not believe the hydrochloric acid process would be eligi-
ble for Program 1 because of the proximity of public receptors (including workers at an adjacent
industrial facility), and, therefore, only carries out the worst-case analysis for the chlorine process.
A distance of 2.80 miles to the endpoint is estimated for a release of 2,000 pounds of chlorine.
Source B must report this worst-case analysis in the RMP.
Example—Source C
Source C is an inorganic chemical manufacturer with two covered processes: a tank containing
10 tons of 70 percent hydrofluoric acid solution and ten one-ton tanks of chlorine on a rack for
wastewater treatment. Source C must carry out one worst-case analysis for regulated toxic sub-
stances for Program 2 and Program 3 processes. Because the toxic endpoint of chlorine is lower
than that of hydrofluoric acid, and because the release rate will probably be greater for a gas
than a solution, Source C decides to carry out the analysis for chlorine as the required worst-
case analysis for toxic substances. Source C believes the hydrofluoric acid process may be eligi-
ble for Program 1 and, therefore, decides to do a worst-case analysis for this process as well.
Results of the worst-case analyses for these two processes are:
• 2.80 miles for 2,000 pounds of chlorine
• 1 mile for 20,000 pounds of 70 percent hydrofluoric acid (released in a diked area)
Homes and businesses are located less than a mile from either process; therefore, neither
process is eligible for Program 1. Source C must report the results of the worst-case analysis for
chlorine.
Example—Source D
Source D is a large chemical manufacturer with 11 regulated substances above their threshold
quantities, including three flammable substances and eight toxic substances. The processes con-
taining flammable substances are: three 18,000-gallon tanks containing 26,000 pounds of eth-
ylene, 66,000 pounds of propylene, and 65,000 pounds of propane; the propane, however, is
used as a fuel and is not subject to the rule.

Annex 5
The largest quantities of toxic substances in processes are: 25,000 pounds of toluene diiso-
cyanate (TDI), 100,000 pounds of chloroform, 25,000 pounds of anhydrous hydrogen chloride,
20,000 pounds of chlorine, 80,000 pounds of epichlorohydrin, 100,000 pounds of methyl chlo-
ride, 10,000 pounds of hydrogen cyanide, and 1,000 pounds of phosgene. For the RMP, Source
D has to report one worst-case analysis for flammable substances and one for toxic substances;
however, Source D believes the processes containing flammable substances may be eligible for
Program 1 and, therefore, chooses to carry out a worst-case analysis for each of these process-
es. In addition, Source D believes the processes containing TDI and chloroform may be eligible
for Process 1, because of the low volatility of TDI and the relatively low toxicity of chloroform,
and decides to carry out analyses to determine eligibility. Source D is not sure which of the other
processes containing toxic substances will give the greatest distance to the endpoint; therefore,
it conducts screening analyses for all these processes.
• The worst-case distances for vapor cloud explosions of the flammable substances are:
∆ 0.24 miles for 26,000 pounds of ethylene; and
∆ 0.32 miles for 66,000 pounds of propylene.
• The worst-case distances to the endpoints for the toxic substances are:
∆ 0.06 miles for 25,000 pounds of TDI;
∆ 0.49 miles for 100,000 pounds of chloroform;
∆ 4.8 miles for 25,000 pounds of hydrogen chloride;
∆ 10 miles for 20,000 pounds of chlorine;
∆ 2.2 miles for 80,000 pounds of epichlorohydrin;
∆ 2.0 miles for 100,000 pounds of methyl chloride;
∆ 5.2 miles for 10,000 pounds of hydrogen cyanide; and
∆ 11 miles for 1,000 pounds of phosgene.
The processes containing ethylene and propylene are located 500 yards (0.28 miles) from a river
(0.5 miles wide). The distance to the endpoint for these two processes does not extend beyond
the river, which is not a recreational area; the processes are eligible for Program 1 (having met
the other criteria). The distance to the endpoints for the TDI process is exceeded by the distance
to public receptors in any direction; therefore, this process is also eligible for Program 1.
Source D reports the worst-case analysis results for ethylene, propylene, and TDI to demonstrate
eligibility for Program 1. It reports the results for propylene as the required worst-case analysis
for flammable substances and the results for phosgene as the required worst-case analysis for
toxic substances.

Annex 5
4.6 Examples of Alternative Releases
Example—Source A
Source A, a retail operation that supplies ammonia and propane, has one covered process: an
ammonia storage tank containing 400,000 pounds of anhydrous ammonia (a regulated toxic
substance). The worst-case consequence analyses for this process indicated it is not eligible for
Program 1. Source A must carry out and report an alternative scenario analysis for the process.
Any reasonable and defensible scenarios can be analyzed for the process.
Example—Source B
Source B is a medium-sized metal products manufacturer with two covered processes contain-
ing regulated toxic substances: a chlorine wastewater treatment plant with 10,000 pounds of
chlorine and a tank containing 50,000 pounds of 37 percent hydrochloric acid. Because of the
proximity of public receptors, neither of these processes is eligible for Program 1. Source B must
carry out and report an alternative scenario analysis for each of these processes. Source B may
analyze any scenarios that are reasonable for the site and processes; the source must be able to
explain its choice of scenarios.
Example—Source C
Source C is an inorganic chemical manufacturer with two covered processes, one containing
20,000 pounds of chlorine and the other containing 20,000 pounds of 70 percent hydrofluoric
acid. Source C’s worst-case analyses indicated that these processes are not eligible for Program
1. Source C must carry out and report an alternative scenario analysis for each of these process-
es. The scenarios may be developed based on any reasonable and defensible assumptions.
Example—Source D
Source D is a large chemical manufacturer with covered processes containing two regulated
flammable substances and eight regulated toxic substances. The worst-case analyses showed
that the processes containing the flammable substances ethylene and propylene are eligible for
Program 1. For flammable substances, Source D need not carry out and report an alternative
scenario analysis.
The worst-case analyses showed that the process containing 25,000 pounds of the toxic sub-
stance toluene diisocyanate (TDI) also is eligible for Program 1; therefore, Source D does not
need to carry out an alternative scenario analysis for TDI. Source D must carry out and report an
alternative scenario analysis for each regulated toxic substance in a covered non-Program 1
process; thus, scenarios must be developed and analyzed for hydrogen chloride, chlorine,
epichlorohydrin, methyl chloride, hydrogen cyanide, chloroform, and phosgene. If the sub-
stances are found in more than one vessel, the analysis should be conducted with respect to the
vessel that presents the greatest relative risk of a release. Analyses of each vessel are not need-
ed. Source D can develop any reasonable scenarios for these substances.

Annex 5
CHAPTER 7
PREVENTION PROGRAM9 (PROGRAM 3)
M any of you will need to do little that is new to comply with the Program 3 prevention
program, because you already have the OSHA PSM program in place. Whether you’re building
on the PSM standard or creating a new program, keep these things in mind.
• EPA and OSHA have different legal authority—EPA for offsite consequences, OSHA for on-site
consequences. If you are already complying with the PSM standard, your process hazard analy-
sis (PHA) team may have to assess new hazards that could affect the public or the environ-
ment offsite. Protection measures that are suitable for workers (e.g., venting releases to the
outdoors) may be the very kind of thing that imperils the public.
• Integrate the elements of your prevention program. You must ensure that a change in any sin-
gle element of your program leads to a review of other elements to identify any effect caused
by the change.
• Most importantly, make accident prevention an institution at your site. Like the entire risk man-
agement program, a prevention program is more than a collection of written documents. It is
a way to make safe operations and accident prevention the way you do business everyday.
7.1 Program 3 Prevention Program and OSHA PSM

The Program 3 prevention program includes the requirements of the OSHA PSM standard.
Whenever we could, EPA used OSHA’s language verbatim. However, there were a few terms
that EPA had to change to reflect the differences between its authority and OSHA’s. For exam-
ple, OSHA regulates to protect workers; EPA’s responsibility is to protect public health and safe-
ty and the environment. Therefore, an “owner or operator” subject to EPA’s rule must investi-
gate catastrophic releases “that present(s) (an) imminent and substantial endangerment to pub-
lic health and the environment,” but an OSHA “employer” would focus its concerns on the
workplace. To clarify these distinctions, we deleted specific references to workplace impacts and
“safety and health” contained in OSHA’s PSM standards. We also used different schedule dates
and references where appropriate. Exhibit 7-1 compares terms in EPA’s rule with their counter-
parts in the OSHA PSM standard.
There are twelve elements in the Program 3 prevention program. Each element corresponds
with a section of subpart D of part 68. Exhibit 7-2 sets out each of the twelve elements, the cor-
responding section numbers, and OSHA references. Two OSHA elements are not included.
Emergency response is dealt with separately in part 68; the OSHA trade secrets requirement
(provision of trade secret information to employees) is beyond EPA’s statutory authority.
9
CRAIM does not consider the notion of program.

Annex 5
Exhibit 7-1
Comparable EPA and OSHA Terms
OSHA Term EPA Term
Highly hazardous substance Regulated substance

Employer Owner or operator
Facility Stationary source
Standard Rule or part
Exhibit 7-2
Summary of Program 3 Prevention Program

(40 CFR Part 68, Subpart D)
Section Title OSHA PSM Reference
§ 68.65 Process Safety Information PSM standard § 1910.119(d)

§ 68.67 Process Hazard Analysis (PHA) PSM standard § 1910.119(e)
§ 68.69 Operating Procedures PSM standard § 1910.119(f)
§ 68.71 Training PSM standard § 1910.119(g)
§ 68.73 Mechanical Integrity PSM standard § 1910.119(j)
§ 68.75 Management of Change PSM standard § 1910.119(l)
§ 68.77 Pre-Startup Review PSM standard § 1910.119(I)
§ 68.79 Compliance Audits PSM standard § 1910.119(o)
§ 68.81 Incident Investigation PSM standard § 1910.119(m)
§ 68.83 Employee Participation PSM standard § 1910.119(c)
§ 68.85 Hot Work Permit PSM standard § 1910.119(k)
§ 68.87 Contractors PSM standard § 1910.119(h)
OSHA provided guidance on PSM in non-mandatory Appendix C to the standard. OSHA has
reprinted this appendix as PSM Guidelines for Compliance (OSHA 3133). The OSHA guidance
is reproduced, reordered to track part 68, in Appendix D. The remainder of this chapter briefly
outlines the major requirements and provides a discussion of any differences between EPA and
OSHA. In some cases, further guidance is provided on the meaning of specific terms. For more
detailed guidance, you should refer to the OSHA guidance in Appendix D.

Annex 5
Qs & As
Implementation and Process
Q. My process is a series of storage and process vessels, connected by piping, contain-

ing several regulated substances, with a few co-located tanks of other substances. Do I
have to implement one prevention program to cover all aspects of the process even if
different operators, different process chemistry, and different hazards are involved in
various parts of the process?
A. You should implement the program in the way that makes sense to you. For a complex
process such as yours, you may need to divide the process into sections (e.g., production
units for particular products, storage units) for the PHA and compliance audits, to keep the
analyses manageable. Operating and maintenance procedures (and the training in these
procedures) should be developed for operating units; combining procedures for different
types of units into a single document may make them harder to use; training operators in
procedures they do not need would waste time and perhaps confuse operators. You may
want to collect and store process safety information by individual units to make it easier to
use. Other parts of the program (contractors, employee participation, procedures for pre-
startup, management of change, and hot work) are likely to be common to all parts of the
process.
Q. I have a tank with more than 10,000 pounds of propane. I use the propane to heat
the offices. The propane is not subject to PSM or the risk management program rule.
The tank, however, is close to equipment that has chlorine above the applicable thresh-
old and is subject to OSHA PSM and Program 3. Is the tank considered part of the
process? Does this affect the program level?
A. If a fire or explosion in the propane tank could cause a release of chlorine or other reg-
ulated substances or interfere with mitigation of such a release, the tank is considered part
of a single process and consequently is subject to both OSHA PSM and program 3.

Annex 5
7.2 Process Safety Information

Exhibit 7-3 briefly summarizes the process safety information requirements.
Where to Go for More Information

Diagrams
You may find it useful to consult Appendix B of OSHA’s PSM final rule, computer soft-
ware programs that do P&IDs, or other diagrams.
Guidance and Reports
Various engineering societies issue technical reports relating to process design. Other
sources you may find useful include:
∆ Guidelines for Process Safety Documentation, Center for Chemical Process Safety
of the American Institute of Chemical Engineers, 1995.
∆ Emergency Relief System Design Using DIERS Technology, American Institute of
Chemical Engineers, 1992.
∆ Emergency Relief System for Runaway Chemical Reactions and Storage Vessels: A
Summary of Multiphase Flow Methods, American Institute of Chemical Engineers,
1986.
∆ Guidelines for Pressure Relief and Emergency Handling Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1998.
∆ Loss Prevention in the Process Industries, Volumes I, II and III, Frank P. Lees,
Butterworths: London 1996.
Exhibit 7-3
Process Safety Information Requirements
For chemicals, you must For process technology, For equipment in the
complete information on: you must provide: process, you must include
information on:
√ Toxicity √ A block flow diagram or √ Materials of construction

√ Permissible exposure limits simplified process flow √ Piping & instrument diagrams
diagram (P&IDs)
√ Physical data
√ Information on process √ Electrical classification
√ Reactivity chemistry
√ Corrosivity √ Relief system design & design
√ Maximum intended inventory basis
√ Thermal & chemical stability of the EPA-regulated chemical
√ Ventilation system design
√ Hazardous effects of √ Safe upper & lower limits for
inadvertent mixing of such items as temperature, √ Design codes &
materials that could pressure, flows, or standards employed
foreseeably occur composition √ Safety systems
√ An evaluation of the √ Material and energy
consequences of deviation balances for processes built
after June 21, 1999

Annex 5
Qs & As
Process Safety Information
Q. What does “materials of construction” apply to and how do I find this information?
A. You must document the materials of construction for all process equipment in a covered
process. For example, you need to know the materials of construction for process vessels,
storage vessels, piping, hoses, valves, and flanges. Equipment specifications should provide
this information.
Q. What does “electrical classification” mean?

A. Equipment and wiring for locations where fire and explosion hazards may exist must
meet requirements based on the hazards. Each room, section, or area must be considered
separately. Equipment should be marked to show Class, Group, and operating temperature
or temperature range. You must determine the appropriate classification for each area and
ensure that the equipment used is suitable for that classification. The equipment covered
includes transformers, capacitors, motors, instruments, relays, wiring, switches, fuses, gen-
erators, lighting, alarms, remote controls, communication, and grounding. Electrical classi-
fication will be included in equipment specifications.
Q. What does “relief system design basis” mean?

A. Relief systems include, but are not limited to, relief valves, relief headers, relief drums,
and rupture disks. Design basis means documenting how the loads and sizes of the relief
system, as well as inlet and outlet sizes, were determined. This includes a description of
overpressure scenarios considered, the scenario that creates the largest load to be relieved,
the assumptions used, and if the device meets a certain code. Relief devices on pressure
vessels must conform to ASME codes. Industry codes (e.g., API RP 520) also provide guid-
ance on scenarios that should be considered and on equations for sizing of devices.
Scenarios you may need to consider include fire, blocked flow, control valve failure, over-
heating, power outage, tube rupture, and cooling water failure. For two-phase flow, you
should review AIChE publications from the Design Institute for Emergency Relief Systems
(DIERS).
Q. What do I have to do for material and energy balances?

A. For new processes, you must document both material and energy inputs and outputs of
a single and consequently is a subject to both OSHA PSM and Program 3.

Annex 5
7.3 Process Hazard Analysis (§ 68.67)

Exhibit 7-4 provides a summary of the requirements for process hazard analyses (PHAs).
EPA/OSHA Differences
You can use a PHA conducted under the OSHA PSM standard as your initial process hazard
analysis. All OSHA PHAs must have been completed by May 1997. Therefore, the only “new”
PHAs will be for non-OSHA Program 3 processes. If the process is subject to OSHA PSM, you
can update and revalidate your PHA on OSHA’s schedule.
Offsite Impacts
You should consider offsite impacts when you conduct a PHA under EPA’s rule (except for an
initial PHA where you are using the PHA conducted for OSHA PSM). If you are in the Program
3 prevention program because you must comply with the PSM standard, you may not have fully
considered offsite consequences because the focus of PSM is worker protection. Practically
speaking, however, there should be few instances where the scenarios considered for OSHA fail
to address offsite impacts. A well-done PHA should identify all failure scenarios that could lead
to significant exposure of workers, the public, or the environment. The only issue that may
require further consideration for part 68 processes is whether any protection measures that
were adequate for worker safety are inadequate for public and environmental safety.
Consider two circumstances—one where OSHA’s PSM standard and EPA’s risk management
program rule lead to the same result, and another where protecting workers could mean endan-
gering the public and the environment. For flammables, any scenario that could affect the pub-
lic almost certainly would have the potential to affect workers; measures taken to protect your
employees likely will protect the public and the environment. For toxics under PSM, however,
you may plan to address a loss of containment by venting toxic vapors to the outside air. In each
circumstance, a PHA should define how the loss of containment could occur. However, for EPA,
the PHA team should reassess venting as an appropriate mitigation measure.
Exhibit 7-4
Process Hazard Analysis Requirements
The PHA must cover: Techniques must be one Other requirements:

or more of:
√ Hazards of the process √ What If √ Analysis must be done by a

√ Identification of previous, √ Checklist team, one member of which
potentially catastrophic has experience in the process,
√ What If/Checklist one member of which is
incidents
√ Hazard and Operability Study knowledgeable in the PHA
√ Engineering and administrative (HAZOP) technique
controls applicable to the
hazards √ Failure Mode and Effects √ A system must be developed
Analysis (FMEA) for addressing the team’s
√ Consequence of failure recommendations and
of controls √ Fault Tree Analysis
documenting resolution and
√ Siting √ Appropriate equivalent corrective actions taken
methodology
√ Human factors √ The PHA must be updated at
least once every five years
√ Qualitative evaluation of health
and safety impacts of control √ PHAs and documentation of
failure actions must be kept for the
life of the process

Annex 5
Updating and Revalidating your PHA

For EPA, you must complete the initial PHA for each Program 3 process not later than June 21,
1999, and update it at least once every five years. You may complete an initial PHA before that
date. You may use an OSHA PHA as your initial PHA, and update and revalidate it every five
years on the OSHA schedule. A PHA completed after August 19, 1996 (the effective date of
part 68) should consider offsite impacts.
Rejecting Team Recommendations

You may not always agree with your PHA team’s recommendations and may wish to reject a
recommendation. OSHA’s compliance directive CPL 2-2.45A-revised states that you may decline
a team recommendation if you can document one of the following:
(1) the analysis upon which the recommendation is based contains factual errors;
(2) the recommendation is not necessary to protect the health of employees or contractors;
(3) an alternative measure would provide a sufficient level of protection; or
(4) the recommendation is infeasible.
For part 68, you should also consider whether recommendations are not necessary to protect
public health and the environment.
Updating Your PHA

You should update or revalidate your PHA whenever there is a new hazard or risk created by
changes to your process. Such changes might include introducing a new process, process equip-
ment, or regulated substance; altering process chemistry that results in any change to safe oper-
ating limits; or other alteration that introduces a new hazard. You might, for example, introduce
a new hazard if you installed a gas pipeline next to a storage tank containing a regulated sub-
stance. Other candidates could be making changes in process constituents that increase the pos-
sibility of runaway reactions or polymerization. EPA recommends that you consider revalidating
your PHA whenever adjoining processes create a hazard. Remember that you have a general
duty to prevent accidents and ensure safety at your source, which may require you to take steps
beyond those specified in the risk management program rule.

Appendix 7-A of this chapter provides a summary of each of the techniques, a description of
the types of processes for which they may be appropriate, and estimates about the time and
staff required for each.
Part 68 and OSHA PSM require that whichever technique or techniques you use, you must have
at least one person on the PHA team who is trained in the use of the technique. Training on
such techniques is available from a number of professional organizations as well as private com-
panies. You may have staff members who are capable of providing this training as well. Many
trade associations publish detailed guidance on methods for conducting a process hazard analy-
sis. You might find the following documents useful.
• Guidelines for Hazard Evaluation Procedures, 2nd Ed. with Worked Examples, Center for
• Evaluating Process Safety in the Chemical Industry, Chemical Manufacturers Association.
• Loss Prevention in the Process Industries, Volumes I, II and III, Frank P. Lees, Butterworths:
London 1996.
• Management of Process Hazards (RP 750), American Petroleum Institute.
• Risk-Based Decision Making (Publication 16288), American Petroleum Institute.

Annex 5
Qs & As
Offsite Consequences
Q. What does EPA mean by “consider offsite consequences”? Do we have to do an

environmental impact assessment (EIA)?
A. EPA does not expect you to do an EIA. Potential consequences to the public and the envi-
ronment are already analyzed in the offsite consequence analysis. In the PHA, EPA only
expects you to identify any failure scenarios that could lead to public exposures and to
examine whether your strategies are adequate to reduce the risk of such exposures.
Q. If I need to revise a PHA to consider offsite consequences, when do I have to do that?

A. In general, for a PHA completed to meet the requirements of OSHA PSM, you should
revise the PHA to consider offsite consequences when you update that PHA. Any PHA for
a covered process completed or updated for OSHA PSM after August 19, 1996, when part
68 was effective, should examine offsite consequences. For example, if you completed an
initial PHA for OSHA PSM in May 1993, OSHA requires that you update that PHA by May
1998. In that update, you should consider offsite consequences. If you complete your ini-
tial PHA for OSHA in May 1995, you must update it by May 2000; PHAs conducted for part
68 must include consideration of offsite consequences at that time.
7.4 Operating Procedures (§ 68.69)

Exhibit 7-5 summarizes what your operating procedures must address. Operating procedures
must be readily accessible to workers who operate or maintain the process. You must review
operating procedures as often as necessary to assure that they reflect current practices and any
changes to the process or facility. You must certify annually that the operating procedures are
current and accurate.

Chapter 6 of this document provides descriptions of each operating phase and when these
phases may not apply to certain operations.
• Guidelines for Process Safety Fundamentals for General Plant Operations, Center for
• Guidelines for Safe Process Operations and Maintenance, Center for Chemical Process
Safety of the American Institute of Chemical Engineers, 1995.
• Guidelines for Writing Effective Operating and Maintenance Procedures, Center for

Annex 5
Exhibit 7-5
Operating Procedures Requirements
Steps for each Operating limits Safety & health Safety systems
operating phase considerations & their functions
√ Initial startup √ Consequences of √ Chemical properties & √ Address whatever

√ Normal operations deviations hazards is applicable
√ Temporary operations √ Steps to avoid, √ Precautions for preventing
correct deviations chemical exposure
√ Emergency shutdown
√ Control measures for
√ Emergency operations exposure
√ Normal shutdown √ QC for raw materials
√ Startup following a and chemical inventory
turnaround or emergency √ Special or unique hazards
shutdown
√ Lockout/tagout
√ Confined space entry
√ Opening process
equipment or piping
√ Entrance into the facility
7.5 Training (§ 68.71)

You are required to train new operators on the operating procedures and cover health and safe-
ty hazards, emergency operations, and safe work practices applicable to the employees’ tasks.
For workers involved in operating the process before June 21, 1999, you may certify in writing
that they are competent to operate the process safely, in accordance with the operating proce-
dures. At least every three years you must provide refresher training (you must consult with
employees involved in operating the process to determine the appropriate frequency). Finally,
you are required to determine that each operator has received and understood the training and
keep a record for each employee with the date of the training and the method used to verify
that the employee understood the training.

• Guidelines for Process Safety Fundamentals for General Plant Operations, Center for
• Guidelines for Technical Planning for On-Site Emergencies, Center for Chemical Process
• Federally Mandated Training and Information (Publication 12000), American Petroleum
Institute.

Annex 5
7.6 Mechanical Integrity (§ 68.73)

You must have a mechanical integrity program for pressure vessels and storage tanks, piping
systems, relief and vent systems and devices, emergency shutdown systems, controls, and
pumps.
Exhibit 7-6 briefly summarizes the other requirements for your mechanical integrity program.

Guidance and Reports
Other sources of guidance and reports you may find useful include:
• Guidelines for Process Equipment Reliability Data with Data Tables, Center for Chemical
Process Safety of the American Institute of Chemical Engineers, 1989.
• Guidelines for Process Safety Documentation, Center for Chemical Process Safety of the
American Institute of Chemical Engineers, 1995.
• Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair, and Alteration
(API 510), American Petroleum Institute.
• Tank Inspection, Repair, Alteration, and Reconstruction (Std 653), American Petroleum
Institute.
Exhibit 7-6
Mechanical Integrity Chart
Written Training Inspection Equipment Quality

procedures & testing deficiencies assurance
√ Establish & √ Train process √ Inspect & test √ Correct equipment √ Establish a QA
implement written maintenance process equipment. deficiencies before program for new
procedures to employees in an √ Use recognized and further use of construction &
maintain the overview of the generally accepted process equipment equipment, newly
integrity of process process and its good engineering or whenever installed equipment,
equipment. hazards. practices. necessary to maintenance
√ Make sure this ensure safety. materials, and spare
√ Follow a schedule parts & equipment.
training covers the that matches the
procedures manufacturer’s
applicable to safe recommendations
job performance. or more frequently
if prior operating
experience indicates
is necessary.
√ Document each
inspection & test
with:
¬ Date,
¬ inspector name,
¬ equipment
identifier,
¬ test or inspection
performed,
¬ results.

Annex 5
7.7 Management of Change (§ 68.75)

Exhibit 7-7 briefly summarizes EPA’s MOC requirements.
Exhibit 7-7
Management of Change Requirements
MOC procedures Employees affected Update process safety Update operating

must address: by the change must: information if: procedures if:
√ Technical basis for the √ Be informed of the change √ A change covered by MOC √ A change covered by
change before startup procedures results in a MOC procedures results
√ Impact on safety and √ Trained in the change change in any PSI required in a change in any
health before startup under EPA’s rule (see operating procedure
§ 67.65) required under EPA’s
√ Modifications to rule (see § 67.69)
operating procedures
√ Necessary time period for
the change
√ Authorization requirements
for proposed change

• Management of Change in Chemical Plants: Learning from Case Histories, Center for
• Plant Guidelines for Technical Management of Chemical Process Safety, Center for Chemical
Process Safety of the American Institute of Chemical Engineers, 1992.
• Management of Process Hazards (RP 750), American Petroleum Institute.
7.8 Pre-Startup Review (§ 68.77)

You must conduct your pre-startup safety review for new stationary sources or modified station-
ary sources when the modification is significant enough to require a change in safety informa-
tion under the management of change element. You must conduct your pre-startup review
before you introduce a regulated substance to a process, and you must address the items listed
in Exhibit 7-8.
Exhibit 7-8
Pre-Startup Review Requirements
Design Adequate PHA/MOC Training

Specifications Procedures
√ Confirm that new or √ Ensure that procedures √ Perform a PHA and resolve √ Confirm that each
modified construction and for safety, operating, or implement any employee involved in
equipment meet design maintenance, and recommendations for the process has been
specifications. emergencies are adequate new process. trained completely.
and in place. √ Meet management of
change requirements for
modified process.

Annex 5
7.9 Compliance Audits (§ 68.79)

You must conduct an audit of the process to evaluate compliance with the prevention program
requirements at least once every three years. At least one person involved in the audit must be
knowledgeable in the process. You must develop a report of the findings and document appro-
priate responses to each finding and document that deficiencies have been addressed. The two
most recent audit reports must be kept on-site.

• Guidelines for Auditing Process Safety Management Systems, Center for Chemical Process
7.10 Incident Investigation (§ 68.81)

Exhibit 7-9 briefly summarizes the steps you must take for investigating incidents.
You must investigate each incident which resulted in, or could have resulted in, a “catastroph-
ic release of a regulated substance.” A catastrophic release is one that “presents an imminent
and substantial endangerment to public health and the environment.”
Although the rule requires you to investigate only those incidents which resulted in, or could
reasonably have resulted in, a catastrophic release, EPA encourages you to investigate all acci-
dental releases. Investigating minor accidents or near misses can help you identify problems that
could result in major releases if left unaddressed.
Exhibit 7-9
Incident Investigation Requirements
√ Initiate an investigation
promptly . . . . . . . . . . . . . . . . . . . . . .Begin investigating no later than 48 hours following the incident.
√ Establish a knowledgeable
investigation team . . . . . . . . . . . . . . .Establish an investigation team to gather the facts, analyze the event, and
develop the how and why of what went wrong. At least one team mem-
ber must have knowledge of the process involved. Consider adding other
workers in the process area where the incident occurred. Their knowl-
edge will be significant and should give you the fullest insight into the
incident.
√ Summarize the investigation
in a report . . . . . . . . . . . . . . . . . . . . .Among other things, the report must identify the factors contributing to
the incident. Remember that identifying the root cause may be more
important than identifying the initiating event. The report must also
include any recommendations for corrective actions. Remember that the
purpose of the report is to help management take corrective action.
√ Address the team’s findings and
recommendations . . . . . . . . . . . . . . .Establish a system to address promptly and resolve the incident report
findings and recommendations; document resolutions and corrective
actions.
√ Review the report with your staff
and contractors . . . . . . . . . . . . . . . . .You must share the report—its findings and recommendations—with
affected workers whose job tasks are relevant to the incident.
√ Retain the report . . . . . . . . . . . . . . . .Keep incident investigation reports for five years.

Annex 5

• Guidelines for Investigating Chemical Process Incidents, Center for Chemical Process Safety of
the American Institute of Chemical Engineers, 1992.
• Guide for Fire and Explosion Investigations (NFPA 921), National Fire Protection Association.
7.11 Employee Participation (§ 68.83)

Exhibit 7-10 briefly summarizes what you must do.
Exhibit 7-10
Employee Participation Requirements
√ Write a plan . . . . . . . . . . . . . . . . . . .Develop a written plan of action regarding how you will implement
employee participation.
√ Consult with employees . . . . . . . . . .Consult your employees and their representatives regarding conducting
and developing PHAs and other elements of process safety management
in the risk management program rule.
√ Provide access to information . . . . . .Ensure that your employees and their representatives have access to PHAs
and all other information required to be developed under the rule.
7.12 Hot Work Permits (§ 68.85)

Exhibit 7-11 briefly summarizes how to meet the hot work permit requirement.
Exhibit 7-11
Hot Work Permit Requirements
√ Issue a hot work permit . . . . . . . . . .You must issue this permit for hot work conducted on or near a
covered process.
√ Implement fire prevention
and protection . . . . . . . . . . . . . . . . . .You must ensure that the fire prevention and protection requirements in
29 CFR 1910.252(a) are implemented before the hot work begins. The
permit must document this.
√ Identify the work . . . . . . . . . . . . . .The permit should indicate the dates authorized for hot work.
√ Indicate the appropriate dates . . . . .The permit must identify the object on which hot work is to be per-
formed.
√ Maintain the permit on file . . . . . . .You must keep the permit on file until workers have completed the hot
work operations.

• Standard for Fire Prevention in Use of Cutting and Welding Processes (NFPA 518), National
Fire Protection Association.
• Standard for Welding, Cutting and Brazing, 29 CFR 1910 Subpart Q.

Annex 5
7.13 Contractors (§ 68.87)

Exhibit 7-12 summarizes both yours and the contractors’ responsibilities where contractors per-
form maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to
a covered process.
Exhibit 7-12
Contractors Chart
You must... Your contractor must...
√ Check safety performance. √ Ensure training for its employees.

When selecting a contractor, you must The contractor must train its employees to
obtain and evaluate information regarding ensure that they perform their jobs safely
the safety performance of the contractor. and in accordance with your source’s safety
√ Provide safety and hazards procedures.
information. √ Ensure its employees know process
You must inform the contractor of potential hazards and applicable emergency
fire, explosion, or toxic release hazards; and actions.
of your emergency response activities as The contractor must assure that contract
they relate to the contractor’s work and the employees are aware of hazards and emer-
process. gency procedures relating to the employ-
√ Ensure safe practices. ees’ work.
You must ensure that you have safe work √ Document training.
practices to control the entrance, presence, The contractor must prepare a record
and exit of contract employees in covered documenting and verifying adequate
process areas. employee training.
√ Verify that the contractor acts √ Ensure its employees are following
responsibly. your safety procedures.
You must verify that the contractor is fulfill- √ Inform you of hazards.
ing its responsibilities. The contractor must tell you of any unique
hazards presented by its work or of any
hazards it finds during performance.
EPA/OSHA Differences
EPA has no authority to require that you maintain an occupational injury and illness log for con-
tract employees. Be aware, however, that OSHA does have this authority, and that the PSM stan-
dard does set this requirement. (See 29 CFR 1910.119(h)(2)(vi).)

• Contractor and Client Relations to Assure Process Safety, Center for Chemical Process Safety
of the American Institute of Chemical Engineers, 1996.
• API/CMA Managers Guide to Implementing a Contractor Safety Program (RP 2221),
American Petroleum Institute.
• Improving Owner and Contractor Safety Performance (RP 2220), American Petroleum
Institute.

Annex 5
APPENDIX 7-A
PHA TECHNIQUES
T his appendix provides descriptions of each of the PHA techniques listed in the OSHA PSM
standard and § 68.67. These descriptions include information on what each technique is, which
types of processes they may be appropriate for, what their limitations are, and what level of
effort is typically associated with each. This information is based on Guidelines for Hazard
Evaluation Procedures, 2nd Ed., published by AIChE/CCPS. If you are interested in more detailed
discussion and worked examples, you should refer to the AIChE/CCPS volume.
Neither the information below nor the full AIChE/CCPS volume will provide you with enough infor-
mation to conduct a PHA. The rule requires that your PHA team include at least one person trained
in the technique you use. Training in PHA techniques is available from a number of organizations.
If you must conduct multiple PHAs, you are likely to need to update your PHAs frequently, or if you
have a complex process that will take several weeks to analyze, you may want to consider train-
ing one or more of your employees. If you have a single process that is unlikely to change more
than once every five years, you may find it more cost-effective to hire a trained PHA leader.
Descriptions of Techniques
Checklists
Checklists are primarily used for processes that are covered by standards, codes, and industry prac-
tices—for example, storage tanks designed to ASME standards, ammonia handling covered by
OSHA (29 CFR 1910.111), propane facilities subject to NFPA-58. Checklists are easy to use and can
help familiarize new staff with the process equipment. AIChE/CCPS states that checklists are a
highly cost-effective way to identify customarily recognized hazards. Checklists are dependent on
the experience of the people who develop them; if the checklist is not complete, the analysis may
not identify hazardous situations.
Checklists are created by taking the applicable standards and practices and using them to gener-
ate a list of questions that seek to identify any differences or deficiencies. If a checklist for a process
does not exist, an experienced person must develop one based on standards, practices, and facil-
ity or equipment experience. A completed checklist usually provides “yes,” “no,” “not applicable,”
and “need more information” answers to each item. A checklist analysis involves touring the
process area and comparing equipment to the list.
AIChE/CCPS estimates that for a small or simple system a checklist will take 2 to 4 hours to pre-
pare, 4 to 8 hours to evaluate the process, and 4 to 8 hours to document the results. For larger or
more complex processes, a checklist will take 1 to 3 days to prepare, 3 to 5 days to evaluate, and
2 to 4 days to document.

Annex 5
What-If
A What-If is a brainstorming approach in which a group of people familiar with the process ask
questions about possible deviations or failures. These questions may be framed as What-If, as
in “What if the pump fails?” or may be expressions of more general concern, as in “I worry
about contamination during unloading.” A scribe or recorder takes down all of the questions
on flip charts or a computer. The questions are then divided into specific areas of investigation,
usually related to consequences of interest. Each area is then addressed by one or more team
members.
What-If analyses are intended to identify hazards, hazardous situations, or accident scenarios.
The team of experienced people identifies accident scenarios, consequences, and existing safe-
guards, then suggests possible risk reduction alternatives. The method can be used to examine
deviations from design, construction, modification, or operating intent. It requires a basic under-
standing of the process and an ability to combine possible deviations from design intent with
outcomes. AIChE describes this as a powerful procedure if the staff are experienced; “otherwise,
the results are likely to be incomplete.”
A What-If usually reviews the entire process, from the introduction of the chemicals to the end.
The analysis may focus on particular consequences of concern. AIChE provides the following
example of a What-If question: “What if the raw material is the wrong concentration?” The
team would then try to determine how the process would respond: “If the concentration of acid
were doubled, the reaction could not be controlled and a rapid exotherm would result.” The
team might then recommend steps to prevent feeding wrong concentrations or to stop the feed
if the reaction could not be controlled.
A What-If of simple systems can be done by one or two people; a more complex process
requires a larger team and longer meetings. AIChE/CCPS estimates that for a small or simple
system a What-If analysis will take 4 to 8 hours to prepare, 1 to 3 days to evaluate the process,
and 1 to 2 days to document the results. For larger or more complex processes, a What-If will
take 1 to 3 days to prepare, 4 to 7 days to evaluate, and 4 to 7 days to document.
What-If/Checklist
A What-If/Checklist combines the creative, brainstorming aspects of the What-If with the sys-
tematic approach of the Checklist. The combination of techniques can compensate for the
weaknesses of each. The What-If part of the process can help the team identify hazards and
accident scenarios that are beyond the experience of the team members. The checklist provides
a more detailed systematic approach that can fill in gaps in the brainstorming process. The tech-
nique is generally used to identify the most common hazards that exist in a process. AIChE states
that it is often the first PHA conducted on a process, with subsequent analyses using more
detailed approaches.
The purpose of a What-If/Checklist is to identify hazards and the general types of accidents that
could occur, evaluate qualitatively the effects of the effects, and determine whether safeguards
are adequate. Usually the What-If brainstorming precedes the use of the checklist, although the
order can be reversed.

Annex 5
The technique usually is performed by a team experienced in the design, operation, and main-
tenance of the process. The number of people required depends on the complexity of the
process. AIChE/CCPS estimates that for a small or simple system a What-If/Checklist analysis will
take 6 to 12 hours to prepare, 6 to 12 hours to evaluate the process, and 4 to 8 hours to doc-
ument the results. For larger or more complex processes, a What-If/Checklist will take 1 to 3
days to prepare, 4 to 7 days to evaluate, and 1 to 3 weeks to document.
HAZOP
The Hazard and Operability Analysis (HAZOP) was originally developed to identify both hazards
and operability problems at chemical process plants, particularly for processes using technolo-
gies with which the plant was not familiar. The technique has been found to be useful for exist-
ing processes as well. A HAZOP requires an interdisciplinary team and an experienced team
leader.
The purpose of a HAZOP is to review a process or operation systematically to identify whether
process deviations could lead to undesirable consequences. AIChE states that the technique can
be used for continuous or batch processes and can be adapted to evaluate written procedures.
It can be used at any stage in the life of a process.
HAZOPs usually require a series of meetings in which, using process drawings, the team system-
atically evaluates the impact of deviations. The team leader uses a fixed set of guide words and
applies them to process parameters at each point in the process. Guide words include “No,”
“More,” “Less,” “Part of,” “As well as,” “Reverse,” and “Other than.” Process parameters
considered include flow, pressure, temperature, level, composition, pH, frequency, and voltage.
As the team applies the guide words to each process step, they record the deviation, with its
causes, consequences, safeguards, and actions needed, or the need for more information to
evaluate the deviation.
HAZOPs require more resources than simpler techniques. AIChE states that a simple process or
a review with a narrow scope may be done by as few as three or four people, if they have the
technical skills and experience. A large or complex process usually requires a team of five to
seven people. AIChE/CCPS estimates that for a small or simple system a HAZOP analysis will take
8 to 12 hours to prepare, 1 to 3 days to evaluate the process, and 2 to 6 days to document the
results. For larger or more complex processes, a HAZOP will take 2 to 4 days to prepare, 1 to 3
weeks to evaluate, and 2 to 6 weeks to document.
Failure Mode and Effects Analysis (FMEA)

A Failure Mode and Effects Analysis (FMEA) evaluates the ways in which equipment fails and
the system’s response to the failure. The focus of the FMEA is on single equipment failures and
system failures. An FMEA usually generates recommendations for increasing equipment reliabil-
ity. FMEA does not examine human errors directly, but will consider the impact on equipment
of human error. AIChE states that FMEA is “not efficient for identifying an exhaustive list of com-
binations of equipment failures that lead to accidents.”

Annex 5
An FMEA produces a qualitative, systematic list of equipment, failure modes, and effects. The
analysis can easily be updated for design or system changes. The FMEA usually produces a table
that, for each item of equipment, includes a description, a list of failure modes, the effects of
each failure, safeguards that exist, and actions recommended to address the failure. For exam-
ple, for pump operating normal, the failure modes would include fails to stop when required,
stops when required to run, seal leaks or ruptures, and pump case leaks or ruptures. The effects
would detail both the immediate effect and the impact on other equipment. Generally, when
analyzing impacts, analysts assume that existing safeguards do not work. AIChE states that
“more optimistic assumptions may be satisfactory as long as all equipment failure modes are
analyzed on the same basis.”
An FMEA requires an equipment list or P&ID, knowledge of the equipment, knowledge of the
system, and responses to equipment failure. AIChE states that on average, an hour is sufficient
to analyze two to four pieces of equipment. AIChE/CCPS estimates that for a small or simple
system an FMEA will take 2 to 6 hours to prepare, 1 to 3 days to evaluate the process, and 1 to
3 days to document the results. For larger or more complex processes, an FMEA will take 1 to
3 days to prepare, 1 to 3 weeks to evaluate, and 2 to 4 weeks to document.
Fault Tree Analysis (FTA)

A Fault Tree Analysis (FTA) is a deductive technique that focuses on a particular accident or main
system failure and provides a method for determining causes of the event. The fault tree is a
graphic that displays the combinations of equipment failures and human errors that can result
in the accident. The FTA starts with the accident and identifies the immediate causes. Each
immediate cause is examined to determine its causes until the basic causes of each are identi-
fied. AIChE states that the strength of FTA is its ability to identify combinations of basic equip-
ment and human failures that can lead to an accident, allowing the analyst to focus preventive
measures on significant basic causes.
AIChE states that FTA is well suited for analyses of highly redundant systems. For systems vul-
nerable to single failures that can lead to accidents, FMEA or HAZOP are better techniques to
use. FTA is often used when another technique has identified an accident that requires more
detailed analysis. The FTA looks at component failures (malfunctions that require that the com-
ponent be repaired) and faults (malfunctions that will remedy themselves once the conditions
change). Failures and faults are divided into three groups: primary failures and faults occur when
the equipment is operating in the environment for which it was intended; secondary failures and
faults occur when the system is operating outside of intended environment; and command
faults and failures are malfunctions where the equipment performed as designed but the sys-
tem that commanded it malfunctioned.
An FTA requires a detailed knowledge of how the plant or system works, detailed process draw-
ings and procedures, and knowledge of component failure modes and effects. AIChE states that
FTAs need well trained and experienced analysts. Although a single analyst can develop a fault
tree, input and review from others is needed.
AIChE/CCPS estimates that for a small or simple system an FTA will take 1 to 3 days to prepare,
3 to 6 days for model construction, 2 to 4 days to evaluate the process, and 3 to 5 days to doc-
ument the results. For larger or more complex processes, an FTA will take 4 to 6 days to pre-
pare, 2 to 3 weeks for model constructions, 1 to 4 weeks to evaluate, and 3 to 5 weeks to doc-
ument.

Annex 5
Other Techniques
The rule allows you to use other techniques if they are functionally equivalent. The AIChE
Guidelines include descriptions of a number of other techniques including Preliminary Hazard
Review, Cause-Consequence Analysis, Event Tree Analysis, and Human Reliability Analysis. You
may also develop a hybrid technique that combines features of several techniques or apply more
than one technique.
Selecting a Technique
Exhibit 7A-1 is adapted from the AIChE Guidelines and indicates which techniques are appro-
priate for particular phases in a process’s design and operation.
Exhibit 7A-1
Applicability of PHA Techniques
Checklist What-If What-If/Checklist HAZOP FMEA FTA
R&D √
Design √ √ √
Pilot Plant Operation √ √ √ √ √ √
Detailed Engineering √ √ √ √ √ √
Construction/Startup √ √ √
Routine Operation √ √ √ √ √ √
Modification √ √ √ √ √ √
Incident Investigation √ √ √ √
Decommissioning √ √ √
Factors in Selecting a Technique

Type of process will affect your selection of a technique. AIChE states that most of the tech-
niques can be used for any process, but some are better suited for certain processes than oth-
ers. FMEA efficiently analyzes the hazards associated with computer and electronic systems;
HAZOPs do not work as well with these. Processes or storage units designed to industry or gov-
ernment standards can be handled with checklists.
AIChE lists What-If, What-If/Checklist, and HAZOP as better able to handle batch processes than
FTA or FMEA because the latter do not easily deal with the need to evaluate the time-depend-
ent nature of batch operations.
Analysis of multiple failure situations is best handled by FTA. Single-failure techniques, such as
HAZOP and FMEA, are not normally used to handle these although they can be extended to
evaluate a few simple accident situations involving more than one event.

Annex 5
AIChE states that when a process has operated relatively free of accidents for a long time, the
potential for high consequence events is low, and there have been few changes to invalidate
the experience base, the less exhaustive techniques, such as a Checklist, can be used. When the
opposite is true, the more rigorous techniques are more appropriate.
A final factor in selecting a technique is time required for various techniques. Exhibit 7A-2 sum-
marizes AIChE’s estimates of the time required for various steps. The full team is usually involved
in the evaluation step; for some techniques, only the team leader and scribe are involved in the
preparation and documentation steps.
Exhibit 7A-2
Time and Staffing for PHA Techniques
Checklist What-If What-If/Checklist HAZOP FMEA FTA
Simple/Small System
# Staff 1-2 2-3 2-3 3-4 1-2 2-3
Preparation 2-4 h 4-8 h 6-12 h 8-12 h 2-6 h 1-3 d
Modeling 3-6 d
Evaluation 4-8 h 1-3 d 6-12 h 1-3 d 1-3 d 2-4 d
Documentation 4-8 h 1-2 d 4-8 h 2-6 d 1-3 d 3-5 d
Large/Complex Process
# Staff 1-2 3-5 3-5 5-7 2-4 2-5
Preparation 1-3 d 1-3 d 1-3 d 2-4 d 1-3 d 4-6 d
Modeling 2-3 w
Evaluation 3-5 d 4-7 d 4-7 d 1-3 w 1-3 w 1-4 w
Documentation 2-4 d 4-7 d 1-3 w 2-6 w 2-4 w 3-5 w
Note:
h = hours
d = days (8 hours)
w = weeks (40 hours)

Annex 5
CHAPTER 8
EMERGENCY RESPONSE PROGRAM
I f you have at least one Program 2 or Program 3 process at your facility, then part 68 may
require you to implement an emergency response program, consisting of an emergency
response plan, emergency response equipment procedures, employee training, and procedures
to ensure the program is up-to-date. This requirement applies if your employees will respond to
some releases involving regulated substances. (See the box on the next page for more informa-
tion on What Is “Response”?)
EPA recognizes that, in some cases (particularly for retailers and other small operations with few
employees), it may not be appropriate for employees to conduct response operations for releas-
es of regulated substances. For example, it would be inappropriate, and probably unsafe, for an
ammonia retailer with only one full-time employee to expect that a tank fire could be handled
without the help of the local fire department or other emergency responder. EPA does not
intend to force such facilities to develop emergency response capabilities. At the same time, you
are responsible for ensuring effective emergency response to any releases at your facility. If your
local public responders are not capable of providing such response, you must take steps to
ensure that effective response is available (e.g., by hiring response contractors).
8.1 Non-responding Facilities (§ 68.90(b))

EPA has adopted a policy for non-responding facilities similar to that adopted by OSHA in its
Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (29 CFR
1910.120), which allows certain facilities to develop an emergency action plan to ensure
employee safety, rather than a full-fledged emergency response plan. If your employees will not
respond to accidental releases of regulated substances, then you need not comply with the
emergency response plan and program requirements. Instead, you are simply required to coor-
dinate with local response agencies to ensure that they will be prepared to respond to an emer-
gency at your facility. (You may want to briefly review the program design issues discussed in
Section 8.2 prior to making this decision.) This will help to ensure that your community has a
strategy for responding to and mitigating the threat posed by a release of a regulated substance
from your facility. To do so, you must ensure that you have set up a way to notify emergency
responders when there is need for a response.
Coordination with local responders also entails the following steps:
• If you have a covered process with a regulated toxic, work with the local emergency planning
entity to ensure that the facility is included in the community emergency response plan pre-
pared under EPCRA regarding a response to a potential release.
• If you have a covered process with a regulated flammable, work with the local fire department
regarding a response to a potential release.

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What Is “Response”?
EPA interprets “response” to be consistent with the definition of response specified under
OSHA’s HAZWOPER Standard. OSHA defines emergency response as “a response effort by
employees from outside the immediate release area or by other designated responders ... to an
occurrence which results, or is likely to result, in an uncontrolled release of a hazardous sub-
stance.” The key factor here is that responders are designated for such tasks by their employer.
This definition excludes “responses to incidental releases of hazardous substances where the
substance can be absorbed, neutralized, or otherwise controlled at the time of release by
employees in the immediate release area, or by maintenance personnel” as well as “responses
to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire,
explosion, or chemical exposure).” Thus, if you expect your employees to take action to end a
small leak (e.g., shutting a valve) or clean up a spill that does not pose an immediate safety or
health hazard, this action could be considered an incidental response and you would not need
to develop an emergency response program if your employees are limited to such activities.
However, due to the nature of the regulated substances subject to EPA’s rule, only the most
minor incidents would be included in this exception. In general, most activities will qualify as a
response due to the immediacy of the dispersion of a toxic plume or spread of a fire, the
volatilization of a spill, and the threat to people on and off site. As a result, if you will have your
employees involved in any substantial way in responding to releases, you will need to develop
an emergency response program. Your emergency response procedures need only apply to
“response” actions; other activities will be described in your maintenance and operating proce-
dures.
Although you do not need to describe these activities in your risk management plan, to docu-
ment your efforts you should keep a record of:
• The emergency contact (i.e., name or organization and number) that you will call for a toxic
or flammable release, and
• The organization that you worked with on response procedures.
The remainder of this chapter is applicable only to those facilities which will conduct a more
extensive level of response operations. As noted above, you may want to review the next sec-
tion before making a decision on whether the facility will take responsibility for conducting any
response activities.
8.2 Elements of an Emergency

Response Program (§ 68.95)
If you will respond to releases of regulated substances with your own employees, your emer-
gency response program must consist of the following elements:
• An emergency response plan (maintained at the facility) that includes:
∆ Procedures for informing the public and emergency response agencies about releases,
∆ Documentation of proper first aid and emergency medical treatment necessary to treat
human exposures, and
∆ Procedures and measures for emergency response.

Annex 5
• Procedures for using, inspecting, testing, and maintaining your emergency response equip-
ment;
• Training for all employees in relevant procedures; and
• Procedures to review and update, as appropriate, the emergency response plan to reflect
changes at the facility and ensure that employees are informed of changes.
What Is a Local Emergency Planning Committee?

Local emergency planning committees (LEPCs) were formed under the Emergency Planning and
Community Right-to-Know Act (EPCRA) of 1986. The committees are designed to serve as a
community forum for issues relating to preparedness for emergencies involving releases of haz-
ardous substances in their jurisdictions. They consist of representatives from local government
(including law enforcement and firefighting), local industry, transportation groups, health and
medical organizations, community groups, and the media. LEPCs:
• Collect information from facilities on hazardous substances that pose a risk to the community;
• Develop a contingency plan for the community based on this information; and
• Make information on hazardous substances available to the general public.
Contact the mayor’s office or the county emergency management office for more information
on your LEPC.
Finally, your plan must be coordinated with the community plan developed under the
Emergency Planning and Community Right-to-Know Act (EPCRA, also known as SARA Title III).
In addition, at the request of local emergency planning or response officials, you must provide
any information necessary for developing and implementing the community plan.
In keeping with the approach outlined in Chapter 6, EPA is not requiring facilities to document
training and maintenance activities. However, as noted above, facilities must maintain an on-site
emergency response plan as well as emergency response equipment maintenance and program
evaluation procedures.
Although EPA’s required elements are essential to any emergency response program, they are
not comprehensive guidelines for creating an adequate response capability. Rather than estab-
lish another set of federal requirements for an emergency response program, EPA has limited
the provisions of its rule to those the CAA mandates. If you have a regulated substance on site,
you are already subject to at least one emergency response rule: OSHA’s emergency action plan
requirements (29 CFR 1910.38). Under OSHA HAZWOPER, any facility that handles “hazardous
substances” (a broad term that includes all of the CAA regulated substances and thus applies
to all facilities with covered processes) must comply with either 29 CFR 1910.38(a) or
1910.120(q). If you have a hazmat team, you are subject to the 29 CFR 1910.120(q) require-
ments. If you determine that the emergency response programs you have developed to comply
with these other rules satisfy the elements listed at the beginning of this section, you will not
have to do anything additional to comply with these elements. Additional guidance on making
this decision is provided in Section 8.5.

Annex 5
In addition, be careful not to confuse writing a set of emergency response procedures in a plan
with developing an emergency response program. An emergency response plan is only one ele-
ment of the integrated effort that makes an emergency response program. Although the plan
outlines the actions and equipment necessary to respond effectively, training, program evalua-
tion, equipment maintenance, and coordination with local agencies must occur regularly if your
plan is to be useful in an emergency: The goal of the program is to enable you to respond quick-
ly and effectively to any emergency. The documents listed in Exhibit 8-1 may be helpful in devel-
oping specific elements of your emergency response program.
Finally, remember that under the General Duty Clause of CAA section 112(r)(1) you are respon-
sible for ensuring that any release from your processes can be handled effectively. If you plan to
rely on local responders for some or all of the response, you must determine that those respon-
ders have both the equipment and training needed to do so. If they do not, you must take steps
to meet any needs, either by developing your own response capabilities, developing mutual aid
agreements with other facilities, hiring response contractors, or providing support to local
responders so they can acquire equipment or training.
Exhibit 8-1
Federal Guidance on Emergency Planning and Response
• Hazardous Materials Emergency Planning Guide (NRT-1), National Response Team, March
1987. Although designed to assist communities in planning for hazmat incidents, this
guide provides useful information on developing a response plan, including planning
teams, plan review, and ongoing planning efforts.
• Criteria for Review of Hazardous Materials Emergency Plans (NRT-1A), National Response
Team, May 1988. This guide provides criteria for evaluating response plans.
• Integrated Contingency Plan, National Response Team (61 FR 28642, June 5, 1996). This
provides guidance on how to consolidate multiple plans developed to comply with various
federal regulations into a single, functional emergency response plan.
• Emergency Response Guidebook, U.S. Department of Transportation, 2000. This guide-
book lists over 1,000 hazardous materials and provides information on their general haz-
ards and recommended isolation distances.
• Response Information Data Sheets (RIDS), U.S. EPA and National Oceanic and Atmospheric
Administration. Developed for use with the Computer-Aided Management of Emergency
Operations (CAMEO) software, these documents outline the properties, hazards, and basic
safety and response practices for thousands of hazardous chemicals.
Relationship to HAZWOPER
If you choose to establish and maintain onsite emergency response capabilities, then you will be
subject to the detailed provisions of the OSHA or EPA HAZWOPER Standard. HAZWOPER cov-
ers preparing an emergency response plan, employee training, medical monitoring of employ-
ees, recordkeeping, and other issues. Call your state or federal district OSHA office for more
information on complying with the HAZWOPER Standard (check the OSHA web site at
www.osha.gov/ for contact names and addresses for OSHA offices). State and local govern-
ments in states without a delegated OSHA program are subject to HAZWOPER under EPA’s 40
CFR part 311.

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How Does the Emergency Response Program Apply?

The requirements for the emergency response program are intended to apply across all covered
processes at a facility. Although certain elements of the program (e.g., how to use specific items
of response equipment) may differ from one process to another, EPA does not intend or expect
you to develop a separate emergency response program for each covered process. With this in
mind, you should realize that your emergency response program will probably apply to your
entire facility, although technically it need only apply to covered processes.
For example, a facility may have two storage tanks, one containing slightly more than a thresh-
old quantity of a regulated substance and one with slightly less. The facility is likely to adopt the
same response approach (e.g., procedures, equipment, and training) for releases whether or not
the process is “covered.” Similarly, a facility may have two adjacent flammable storage tanks,
one containing a regulated substance above the threshold and the other containing another,
unlisted flammable. The facility is likely to adopt the same approach for releases whether or not
the process is “covered.”
8.3 Developing an Emergency Response Program

The development of an emergency response program should be approached systematically. As
described in Section 8.2, all facilities complying with these emergency response program provi-
sions will already be subject to OSHA HAZWOPER. As a result, you are likely to fall into one of
two groups:
• You have already met several federal requirements for emergency planning and are interest-
ed in developing an integrated program to minimize duplication (Section 8.4).
• You have a pre-existing emergency response program (perhaps based on an internal policy
decision) and need to determine what additional activities you will need to conduct (Section
8.5).
Steps for Getting Started

The following steps outline a systematic approach that can serve as the framework for the pro-
gram development process in each of these cases. Following these initial steps will allow you to
conduct the rest of the process more efficiently.
Form an emergency response program team.
The team should consist of employees with varying degrees of emergency response responsibil-
ities, as well as personnel with expertise from each functional area of your facility. You should
consider including persons from the following departments or areas:
• Maintenance;
• Operations or line personnel;
• Upper and line management;
• Legal;
• Fire and hazmat response;
• Environmental, health, and safety affairs;
• Training;
• Security;
• EPCRA section 302 emergency coordinator (if one exists);
• Public relations; and
• Personnel.

Annex 5
Of course, the membership of the team will need to be more or less extensive depending on
the scope of the emergency response program. A three-member team may be appropriate for
a small facility with a couple of process operators cross-trained as fire responders, while a facil-
ity with its own hazmat team and environmental affairs department may need a dozen repre-
sentatives.
Collect relevant facility documents.
Members of the development team should collect and review all of the following:
• Site plans:
• Existing emergency response plans and procedures;
• Submissions to the LEPC under EPCRA sections 302 and 303;
• Hazard evaluation and release modeling information;
• Hazard communication and emergency response training;
• Emergency drill and exercise programs;
• After-action reports and response critiques; and
• Mutual aid agreements.
Identify existing programs to coordinate efforts.

The team should identify any related programs from the following sources:
• Corporate- and industry-sponsored safety, training, and planning efforts; and
• Federal, state, and local government safety, training, and planning efforts (see Exhibit 8-2).
Exhibit 8-2
Federal Emergency Planning Regulations
The following is a list of some of the federal emergency planning regulations:

• EPA’s Oil Pollution Prevention Regulation (SPCC and Facility Response Plan
Requirements) - 40 CFR part 112.7(d) and 112.20-.21;
• MM’s Facility Response Plan Regulation - 30 CFR part 254;
• RSPA’s Pipeline Response Plan Regulation - 49 CFR part 194;
• USCG’s Facility Response Plan Regulation - 33 CFR part 154, Subpart F;
• EPA’s Risk Management Program Regulation - 40 CFR part 68;
• OSHA’s Emergency Action Plan Regulation - 29 CFR 1910.38(a);
• OSHA’s Process Safety Standard - 29 CFR 1910.119;
• OSHA’s HAZWOPER Regulation - 29 CFR 1910.120;
• OSHA’s Fire Brigade Regulation - 29 CFR 1910.156;
• EPA’s Resource Conservation and Recovery Act Contingency Planning Requirements
- 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52;
• EPA’s Emergency Planning and Community Right-to-Know Act Requirements - 40
CFR part 355. (These planning requirements apply to communities, rather than facil-
ities, but will be relevant when facilities are coordinating with local planning and
response entities).
• EPA’s Storm Water Regulations - 40 CFR 122.26.
Facilities may also be subject to state and local planning requirements.

Annex 5
Determine the status of each required program element.

Using the information collected, you should assess whether each required program element (see
Section 8.2) is:
• In place and sufficient to meet the requirements of part 68;
• In place, but not sufficient to meet the requirements of part 68; or
• Not in place.
This examination will shape the nature of your efforts to complete the emergency response pro-
gram required under the risk management program. For example, if you are already in compli-
ance with OSHA’s HAZWOPER Standard, you have probably satisfied most, if not all, of the
requirements for an emergency response program.
Section 8.6 explains the intent of each of EPA’s requirements to help you determine whether you
are already in compliance.
Take additional actions as necessary.
Tailoring Your Program to Your Hazards

If your processes and chemicals pose a variety of hazards, it may be necessary to tailor some ele-
ments of your emergency response program to these specific hazards. Unless each part of your
program element is appropriate to the release scenarios that may occur, your emergency
response program cannot be fully effective. Your program should include core elements that are
appropriate to most of the scenarios, supplemented with more specific response information for
individual scenarios. This distinction should be reflected in your emergency response plan, which
should explain when to access the general and specific response information.
To do this, you will need to consider the following four steps:
• Identify and characterize the hazards for each covered process. The process hazards analysis
(see Chapter 7) or hazard review (see Chapter 6) and offsite consequence analysis (see
Chapter 4) should provide this information.
• For each program element, compare the activities involved in responding to each type of acci-
dent scenario and decide if they are different enough to require separate approaches. For
example, response equipment and training will likely be different for releases of toxic versus
flammable gases.
• For those program elements that may be chemical- or process-specific, identify what and how
systems and procedures need to be modified. For example, if existing mitigation systems are
inadequate for responding to certain types of releases, you will need to consider what addi-
tional types of equipment are needed.
• Consider possible causes of emergencies in developing your emergency response program.
You should consider both the hazards at your facility and in the surrounding environment. In
making this determination, you should consider your susceptibility to:
∆ Fires, spills, and vapor releases;
∆ Floods, temperature extremes, tornadoes, earthquakes, and hurricanes;
∆ Loss of utilities, including power failures; and
∆ Train derailments, bomb threats, and other man-made disasters.

Annex 5
8.4 Integration of Existing Programs

A number of other federal statutes and regulations require emergency response planning (see
Exhibit 8-2). On June 5, 1996, the National Response Team (NRT), a multi-agency group chaired
by EPA, published the Integrated Contingency Plan Guidance in the Federal Register (61 FR
28642). This guidance is intended to be used by facilities to prepare emergency response plans
for responding to releases of oil and hazardous substances. The guidance provides a mechanism
for consolidating multiple plans that you prepared to comply with various regulations into a sin-
gle, functional emergency response plan or integrated contingency plan (ICP).
The ICP guidance does not change existing regulatory requirements; rather, it provides a format
for organizing and presenting material currently required by regulations. Individual regulations
are often more detailed than the ICP guidance. To ensure full compliance, you will still need to
read and comply with all of the federal regulations that apply. The guidance contains a series of
matrices designed to assist you in consolidating various plans while documenting compliance
with these federal requirements.
The NRT and the agencies responsible for reviewing and approving plans to which the ICP
option applies have agreed that integrated response plans prepared according to the guidance
will be acceptable and the federally preferred method of response planning. The NRT anticipates
that future development of all federal regulations addressing emergency response planning will
incorporate use of the ICP guidance.
As shown in Exhibit 8-3, the ICP format is organized into three main sections: an introductory
section, a core plan, and a series of supporting annexes. The notice published in the Federal
Register explains the intended structure of the ICP and provides detailed annotation. EPA’s
EPCRA/RCRA/Superfund Hotline can supply you with a copy and answer general questions
about the guidance; for further information and guidance on complying with specific regula-
tions, you should contact the appropriate federal agencies.
An Approach to Integration
Like many other facilities, you may have opted to develop and maintain separate documents
and procedures for each federal emergency planning requirement. However, meeting the Clean
Air Act emergency response requirements provides you with the opportunity to integrate sever-
al existing programs. Integrating the various emergency response efforts you conduct (those
mandated both by management and by government) will increase the usefulness of your emer-
gency preparedness activities and decrease the burden associated with maintaining multiple
programs. Integration will improve your chances to respond effectively to a release by stream-
lining your training and eliminating overlaps and conflicts in the roles and responsibilities of your
employees under different programs. However, it is important to note that, although you are
encouraged to integrate your emergency response efforts, it is not a requirement of the Clean
Air Act.
If you have multiple emergency response programs, you should consider integrating them into
a single program with procedures for responding to your most likely release scenarios. The ICP
Guidance discussed above provides comparison matrices for a number of federal programs that
will help you accomplish the following:
• Distinguish the individual regulatory provisions with which you must comply, and
• Identify where an integrated effort can meet the requirements of two or more regulations.
The requirements of various emergency response programs may be similar, but the subtle dif-
ferences between requirements will likely determine the degree to which integration is a feasi-
ble and beneficial undertaking (see Exhibit 8-4). To help you identify the relevant rules and reg-
ulations, the ICP Guidance provides section-by-section regulatory citations for each emergency
response program element for each of the regulatory programs listed in Exhibit 8-2.

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Exhibit 8-3
Integrated Contingency Plan Outline
Section I—Plan Introduction Elements

1. Purpose and Scope of Plan Coverage
2. Table of Contents
3. Current Revision Date
4. General Facility Identification Information
a. Facility name
b. Owner/operator/agent (include physical and mailing address and phone number)
c. Physical address of the facility (include county/parish/borough, latitude/longitude,
and directions)
d. Mailing address of the facility (correspondence contact)
e. Other identifying information (e.g., ID numbers, SIC Code, oil storage start-up date)
f. Key contact(s) for plan development and maintenance
g. Phone number for key contact(s)
h. Facility phone number
i. Facility fax number
Section II—Core Plan Elements
1. Discovery
2. Initial Response
a. Procedures for internal and external notifications (i.e., contact, organization name, and phone
number of facility emergency response coordinator, facility response team personnel, federal,
state, and local officials)
b. Establishment of a response management system
c. Procedures for preliminary assessment of the situation, including an identification of incident
type, hazards involved, magnitude of the problem, and resources threatened
d. Procedures for establishment of objectives and priorities for response to the specific incident,
including:
(1) Immediate goals/tactical planning (e.g., protection of workers and public as priorities)
(2) Mitigating actions (e.g., discharge/release control, containment, and recovery, as
appropriate)
(3) Identification of resources required for response
e. Procedures for implementation of tactical plan
f. Procedure for mobilization of resources
3. Sustained Actions
4. Termination and Follow-Up Actions

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Exhibit 8-3
Integrated Contingency Plan Outline (continued)
Section III—Annexes
Annex 1: Facility and Locality Information
a. Facility maps
b. Facility drawings
c. Facility description/layout, including identification of facility hazards and vulnerable
resources and populations on and off the facility which may be impacted by an incident
Annex 2: Notification
a. Internal notifications
b. Community notifications
c. Federal and state agency notifications
Annex 3: Response Management System
a. General
b. Command
c. Operations
d. Planning
e. Logistics
f. Finance/procurement/administration
Annex 4: Incident Documentation
a. Post accident investigation
b. Incident history
Annex 5: Training and Exercises/Drills
Annex 6: Response Critique and Plan Review and Modification Process
Annex 7: Prevention
Annex 8: Regulatory Compliance and Cross-Reference Matrices
Exhibit 8-4
Sample Integration Effort
Written site evacuation procedures are required by several emergency planning regulations.
In keeping with the spirit of the ICP Guidance, rather than preparing multiple sets of evac-
uation procedures (and possibly introducing dangerous errors as components are revised
and updated), you may want to compile a single set of procedures that includes the specif-
ic elements mandated by all of the regulations. For example, if you have one or more adja-
cent operating areas that evacuate to the same location(s), this approach will be very effec-
tive. On the other hand, if you have widely separated operating areas with different evacu-
ation routes and assembly points, integration will be less useful.
Area Signal Escape Assembly Point Supervisor

Route
Shipping Room Horn Blue Front Gate Shipping Supervisor

Control Room Horn Green Parking Lot Lead Operator
Tank Farm Radio Red Side Gate Inspector

Annex 5
8.5 Have I Met Part 68 Requirements?

EPA believes that the creation of multiple response plans to meet slightly different federal or
state standards is counterproductive, diverting resources that could be used to develop better
response capabilities. Therefore, as part of the overall effort to reduce the imposition of poten-
tially duplicative or redundant federal requirements, EPA has limited its requirements for the
emergency response program to the general provisions mandated by Congress, as described in
Section 8.2.
As a result, EPA believes that facilities subject to other federal emergency planning requirements
may have already met the requirements of these regulations. For example, plans developed to
comply with other EPA contingency planning requirements and the OSHA HAZWOPER rule (29
CFR 1910.120) will likely meet the requirements for the emergency response plan (and most of
the requirements for the emergency response program). The following discussion presents some
general guidance on what actions you need to take for each of the required elements.
Emergency Response Plan

If you already have a written plan to comply with another planning regulation, you do not need
to write another plan, but only add to it as necessary to cover the elements listed below.
Keep in mind:
At a minimum, your plan must describe:
• Your procedures for informing the public and offsite emergency response agencies of a
release. This must include the groups and individuals that will be contacted and why, the
means by which they will be contacted, the time frame for notification, and the information
that will be provided.
• The proper first aid and emergency medical treatment for employees, first responders, and
members of the public who may have been exposed to a release of a regulated substance.
This must include standard safety precautions for victims (e.g., apply water to exposed skin
immediately) as well as more detailed information for medical professionals. You must also
indicate who is likely to be responsible for providing the appropriate treatment: an employee,
an employee with specialized training, or a medical professional.
• Your procedures for emergency response in the event of a release of a regulated substance.
This must include descriptions of the actions to be taken by employees and other individuals
on-site over the entire course of the release event:
∆ Activation of alarm systems and interpretation of signals;
∆ Safe evacuation, assembly, and return;
∆ Selection of response strategies and incident command structure;
∆ Use of response equipment and other release mitigation activities; and
∆ Post-release equipment and personnel cleanup and decontamination.
Planning Coordination
One of the most important issues in an emergency response program is deciding which
response actions will be assigned to employees and which will be handled by offsite personnel.
As a result, talking to public response organizations will be critical when you develop your emer-
gency response procedures. Although EPA is not requiring you to be able to respond to a release
alone, you should not simply assume that local responders will be able to manage an emer-
gency. You must work with them to determine what they can do, and then expand your own
abilities or establish mutual aid agreements or contracts to handle those situations for which you
lack the appropriate training or equipment.

Annex 5
If you have already coordinated with local response agencies on how to respond to potential
releases of regulated substances and you have ensured an effective response, you do not need
to take any further action.
Keep in mind:
Your coordination must involve planning for releases of regulated substances from all covered
processes and must cover:
• What offsite response assistance you will require for potential release scenarios, including
fire-fighting, security, and notification of the public;
• How you will request offsite response assistance; and
• Who will be in charge of the response operation and how will authority be delegated down
the internal and offsite chain of command.
Coordination equivalent to that required for planning for extremely hazardous substances under
EPCRA sections 302-303 will be considered sufficient to meet this requirement. A more detailed
discussion of this element is provided in 8.6.
Emergency Equipment
If you already have written procedures for using and maintaining your emergency response
equipment, you do not need to write new procedures.
Keep in mind:
Your procedures must apply to any emergency equipment relevant to a response involving a
covered process, including all detection and monitoring equipment, alarms and communica-
tions systems, and personal protective equipment not used as part of normal operations (and
thus not subject to the prevention program requirements related to operating procedures and
maintenance). The procedures must describe:
• How and when to use the equipment properly;
• How and when the equipment should receive routine maintenance; and
• How and when the equipment should be inspected and tested for readiness.
Written procedures comparable to those necessary for process-related equipment under the
OSHA PSM Standard and EPA’s Program 2 and 3 Prevention Programs will be considered suffi-
cient to meet this requirement.
Employee Training
If you already train your employees in how to respond to (or evacuate from) releases of regulat-
ed substances, then you do not need a new training program.
Keep in mind:
Your training must address the actions to take in response to releases of regulated substances
from all covered processes. The training should be based directly on the procedures that you
have included in your emergency response plan and must be given to all employees and con-
tractors on site.
Individuals should receive training appropriate to their responsibilities:
• If they will only need to evacuate, then their training should cover when and how to evacu-
ate their location.
• If they may need to activate an alarm system in response to a release event, then their train-
ing should cover when and how to use the alarm system.
• If they will serve on an emergency response team, then their training should cover how to use
emergency equipment and how the incident command system works.

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Emergency response training conducted in compliance with the OSHA HAZWOPER Standard
and 29 CFR 1910.38 will be considered sufficient to meet this requirement.
Response Plan Evaluation

If you already have a formal practice for regular review and updates of your plan based on
changes at the facility, you do not need to develop additional procedures.
Keep in mind:
You must also identify the types of changes to the facility that would cause the plan to be updat-
ed (e.g., a new covered process) and include a method of communicating any changes to the
plan to your employees (e.g., through training). You may want to set up a regular schedule on
which you review your entire emergency response plan and identify any special conditions (e.g.,
a drill or exercise) that could result in an interim review.
8.6 Coordination with Local Emergency

Planning Entities (§ 68.95 (c))
Once you determine that you have at least one covered process, you should open communica-
tions with local emergency planning and response officials, including your local emergency plan-
ning committee if one exists. Because your LEPC consists of representatives from many local
emergency planning and response agencies, it is likely to be the best source of information on
the critical emergency response issues in your community. However, in some cases, there may
not be an active LEPC in your community. If so, or if your state has not designated your com-
munity as an emergency planning district under EPCRA, you will likely need to contact local
agencies individually to determine which entities (e.g., fire department, emergency manage-
ment agency, police department, civil defense office, public health agency) have jurisdiction for
your facility.
Key Coordination Issues

If you have any of the toxic regulated substances above the threshold quantity, you should have
already designated an emergency coordinator to work with the LEPC on chemical emergency
preparedness issues (a requirement for certain facilities regulated under EPCRA). If you have not
(or if your facility has only regulated flammable substances), you may want to do so at this time.
The emergency coordinator should be the individual most familiar with your emergency
response program (e.g., the person designated as having overall responsibility for this program
in your management system—see Chapter 5).
Involvement in the activities of your LEPC can have a dramatically positive effect on your emer-
gency response program, as well as on your relationship with the surrounding community. Your
LEPC can provide technical assistance and guidance on a number of topics, such as conducting
response training and exercises, developing mutual aid agreements, and evaluating public alert
systems. The coordination process will help both the community and the facility prepare for an
emergency, reducing expenditures of time and money, as well as helping eliminate redundant
efforts.
You should consider providing the LEPC with draft versions of any emergency response program
elements related to local emergency planning efforts. This submission can initiate a dialogue
with the community on potential program improvements and lead to coordinated training and
exercise efforts. In return, your LEPC can support your emergency response program by provid-
ing information from its own emergency planning efforts, including:

Annex 5
• Data on wind direction and weather conditions, or access to local meteorological data, to
help you make decisions related to the evacuation of employees and public alert notifica-
tion;
• Lists of emergency response training programs available in the area for training police, med-
ical, and fire department personnel, to help you identify what training is already available;
• Schedules of emergency exercises designed to test the community response plan to spur
coordinated community-facility exercises;
• Lists of emergency response resources available from both public and private sources to help
you determine whether and how a mutual aid agreement could support your program; and
• Details on incident command structure, emergency points of contact, availability of emer-
gency medical services, and public alert and notification systems.
Upon completion of your emergency response plan, you should coordinate with the LEPC, local
response organizations, local hospitals, and other response organizations (e.g., state hazmat
team) and offer them a copy of the plan. In some instances, only a portion of the plan may be
of use to individuals or organizations; in such cases, you should consider making only that por-
tion of the plan available. For instance, it may be appropriate to send a hospital only the sec-
tions of your plan that address emergency medical procedures and decontamination.
You may also want to provide your LEPC and local response entities with a description of your
emergency response program elements, as well as any important subsequent amendments or
updates, to ensure that the community is aware of the scope of your facility response efforts
prior to an emergency. Although the summary of your emergency response program will be
publicly available as part of your RMP, this information may not be as up-to-date or as compre-
hensive. Remember, the LEPC has been given the authority under EPCRA and Clean Air Act reg-
ulations to request any information necessary for preparing the community response plan.
Planning for Flammable Substances

In the case of regulated flammable substances, the fire department with jurisdiction over your
facility may already be conducting fire prevention inspections and pre-planning activities under
its own authority. Your participation in these efforts (as requested) will allow local responders to
gather the information they need and prepare for an emergency. If there is no local fire depart-
ment, or if there is only a volunteer fire department in your area, you may need to contact other
local response or planning officials (e.g., police) to determine how you can work with the com-
munity.

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CHAPTER 11
COMMUNICATION WITH THE PUBLIC
Once you have prepared and submitted your RMP, EPA will make it available to the public. Public
availability of the RMP is a requirement under section 114(c) of the Clean Air Act (the Act pro-
vides for protection of trade secrets, and EPA will accordingly protect any portion of the RMP
that contains Confidential Business Information). Therefore, you can expect that your commu-
nity will discuss the hazards and risks associated with your facility as indicated in your RMP. You
will necessarily be part of such discussions. The public and the press are likely to ask you ques-
tions because only you can provide specific answers about your facility and your accident pre-
vention program. This dialogue is a most important step in preventing chemical accidents and
should be encouraged. You should respond to these questions honestly and candidly. Refusing
to answer, reacting defensively, or attacking the regulation as unnecessary are likely to make
people suspicious and willing to assume the worst. A basic fact of risk communication is that
trust, once lost, is very hard to regain. As a result, you should prepare as early as possible to
begin talking about these issues with the community, Local Emergency Planning Committees
(LEPCs), State Emergency Response Commissions (SERCs), other local and state officials, and
other interested parties.
Communication with the public can be an opportunity to develop your relationship with the
community and build a level of trust among you, your neighbors, and the community at large.
By complying with the RMP rule, you are taking a number of steps to prevent accidents and pro-
tect the community. These steps are the individual elements of your risk management program.
A well-designed and properly implemented risk management program will set the stage for
informative and productive dialogue between you and your community. The purpose of this
chapter is to suggest how this dialogue may occur. In addition, note that some industries have
developed guidance and other materials to assist in this process; contact your trade association
for more information.
11.1 Basic Rules of Risk Communication

Risk communication means establishing and maintaining a dialogue with the public about the
hazards at your operation and discussing the steps that have been or can be taken to reduce
the risk posed by these hazards. Of particular concern under this rule are the hazards related to
the chemicals you use and what would happen if you had an accidental release.
Many companies, government agencies, and other entities have confronted the same issue you
may face: how to discuss with the public the risks the community is subject to. Exhibit 11-1 out-
lines seven “rules” of risk communication that have been developed based on many experi-
ences of dealing with the public about risks.
A key message of these “rules” is the importance and legitimacy of public concerns. People
generally are less tolerant of risks they cannot control than those they can. For example, most
people are willing to accept the risks of driving because they have some control over what hap-
pens to them. However, they are generally more uncomfortable accepting the risks of living near
a facility that handles hazardous chemicals if they feel that they have no control over whether
the facility has an accident. The Clean Air Act’s provision for the public availability of RMPs gives
the public an opportunity to take part in reducing the risk of chemical accidents that might occur
in their community.

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Exhibit 11-1
Seven Cardinal Rules of Risk Communication
1. Accept and involve the public as a legitimate partner

2. Plan carefully and evaluate your efforts
3. Listen to the public’s specific concerns
4. Be honest, frank, and open
5. Coordinate and collaborate with other credible sources
6. Meet the needs of the media
7. Speak clearly and with compassion
Hazards Versus Risks

Dialogue in the community will be concerned with both hazards and risks; it is useful to be clear
about the difference between them.
Hazards are inherent properties that cannot be changed. Chlorine is toxic when inhaled or
ingested; propane is flammable. There is little that you can do with these chemicals to change
their toxicity or flammability. If you are in an earthquake zone or an area affected by hurricanes,
earthquakes and hurricanes are hazards. When you conduct your hazard review or process haz-
ards analysis, you will be identifying your hazards and determining whether the potential expo-
sure to the hazard can be reduced in any way (e.g., by limiting the quantity of chlorine stored
on-site).
Risk is usually evaluated based on several variables, including the likelihood of a release occur-
ring, the inherent hazards of the chemicals combined with the quantity released, and the poten-
tial impact of the release on the public and the environment. For example, if a release during
loading occurs frequently, but the quantity of chemical released is typically small and does not
generally migrate off site, the overall risk to the public is low. If the likelihood of a catastrophic
release occurring is extremely low, but the number of people who could be affected if it
occurred is large, the overall risk may still be low because of the low probability that a release
will occur. On the other hand, if a release occurs relatively frequently and a large number of peo-
ple could be affected, the overall risk to the public is high.
The rule does not require you to assess risk in a quantitative way because, in most cases, the
data you would need to estimate risk levels (e.g., one in 100 years) are not available. Even in
cases where data such as equipment failure rates are available, there are large uncertainties in
using that data to determine a numerical risk level for your facility, because your facility is prob-
ably not the same as other facilities, and your situation may be dynamic. Therefore, you may
want to assign qualitative values (high, medium, low) to the risks that you have identified at your
facility, but you should be prepared to explain the terms if you do. For example, if you believe
that the worst-case release is very unlikely to occur, you must give good reasons; you must be
able to provide specific examples of measures that you have taken to prevent such a release,
such as installation of new equipment, careful training of your workers, rigorous preventive
maintenance, etc. You should also be able to show documentation to support your claim.

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Who Will Ask Questions?

Your Local Emergency Planning Committee (LEPC) and other facilities can help you identify indi-
viduals in the following groups who may be reviewing RMP data and asking questions.
Interested parties may include:
1) Persons living near the facility and elsewhere in the community or working at a neighboring
facility
2) Local officials from zoning and planning boards, fire and police departments, health and
building code officials, elected officials, and various county and state officials
3) Your employees
4) Special interest groups including environmental organizations, chambers of commerce,
unions, and various civic organizations
5) Journalists, reporters, and other media representatives
6) Medical professionals, educators, consultants, neighboring companies and others with spe-
cial expertise or interests
In general, people will be concerned about accident risks at your facility, how you manage the
risks, and potential impacts of an accident on health, safety, property, natural resources, com-
munity infrastructure, community image, property values, and other matters. Those individuals
in the public and private sector who are responsible for dealing with these impacts and the asso-
ciated risks also will have an interest in working with you to address these risks.
What Information about Your Facility Is Available to the

Public?
Even though the non-confidential information you provide in your RMP is available to the pub-
lic, it is likely that people will want additional information. Interested parties will know that you
retain additional information at your facility (e.g., documentation of the results of the offsite
consequence analysis reported in your RMP) and are required to make it available to EPA or its
implementing agency during inspections or compliance audits. Therefore, they may request
such information. EPA encourages you to provide public access to this information. If EPA or its
implementing agency were to request this information, it would be available to the public under
section 114(c) of the CAA.
The public may also be interested in other information relevant to risk management at your facil-
ity, such as:
• Submissions under sections 302, 304, 311-312, and 313 of the Emergency Planning and
Community Right to Know Act (EPCRA) reporting on chemical storage and releases, as well
as the community emergency response plan prepared under EPCRA section 303.
• Other reports on hazardous materials made, used, generated, stored, spilled, released and
transported, that you submitted to federal, state, and local agencies.
• Reports on workplace safety and accidents developed under the Occupational Safety and
Health Act that you provide to employees, who may choose to make the information publicly
available, such as medical and exposure records, chemical data sheets, and training materials.
• Any other information you have provided to public agencies that can be accessed by mem-
bers of the public under the federal Freedom of Information Act and similar state laws (and
that may have been made widely available over the Internet).
• Any published materials on facility safety (either industry or site-specific), such as agency
reports on facility accidents, safety engineering manuals and textbooks, and professional jour-
nal articles on facility risk management.

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11.2 Sample Questions for Communicating

with the Public
Smaller businesses may not have the resources or time to develop the types of outreach pro-
grams, described later in this chapter, that many larger chemical companies have used to han-
dle public questions and community relations. For many small businesses, communication with
the public will usually occur when you are asked questions about information in your RMP. It is
important that you respond to these questions constructively. Go beyond just answering ques-
tions; discuss what you have done to prevent accidents and work with the community to reduce
risks. The people in your community will be looking to you to provide answers.
To help you establish a productive dialogue with the community, the rest of this section presents
questions you are likely to be asked and a framework for answering them. These are elements
of the public dialogue that you may anticipate. The person from your facility designated as
responsible for communicating with the public should review the following and talk to other
community organizations to determine which questions are most likely to be raised and identi-
fy other foreseeable issues. Remember that others in the community, notably LEPCs and other
emergency management organizations, are also likely to be asked these and other similar ques-
tions. You should consider the unique features of your facility, your RMP, and your historical rela-
tionship with the community (e.g., prior accidents, breakdowns in the coordination of emer-
gency response efforts, and management-labor disputes), and work together with these other
organizations to answer these questions for your situation and to resolve the issues associated
with them.
What does your worst-case release distance mean?

The distance is intended to provide an estimate of the maximum possible area that might be
affected under catastrophic conditions. It is intended to ensure that no potential risks to public
health are overlooked, but the distance to an endpoint estimated under worst-case conditions
should not be considered a “public danger zone.”
In most cases, the mathematical models used to analyze the worst-case release scenario as
defined in the rule may overestimate the area that would be impacted by a release. In other
cases, the models may underestimate the area. For distances greater than approximately six
miles, the results of toxic gas dispersion models are especially uncertain, and you should be pre-
pared to discuss such possibilities in an open, honest manner.
Reasons that modeling may underestimate the distance generally relate to the inability of some
models to account for site-specific factors that might tend to increase the actual endpoint dis-
tance. For example, assume a facility is located in a river valley and handles dense toxic gases
such as chlorine. If a release were to occur, the river valley could channel the toxic cloud much
farther than it might travel if it were to disperse in a location with generally flat terrain. In such
cases, the actual endpoint distance might be longer than that predicted using generic lookup
tables.
Reasons that the area may be overestimated include:
• For toxics, the weather conditions (very low wind speed, calm conditions) assumed for a
worst-case release scenario are uncommon and probably would not last as long as the time
the release would take to travel the distance estimated. If weather conditions are different, the
distance would be much shorter.
• For flammables, although explosions can occur, a release of a flammable is more likely to dis-
perse harmlessly or burn. If an explosion does occur, however, this area could be affected by
the blast; debris from the blast could affect an even broader area.

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• In general, some models cannot take into account other site-specific factors that might tend
to disperse the chemicals more quickly and limit the distance.
Note: When estimating worst-case release distances, the rule does not allow facilities to take
into account active mitigation systems and practices that could limit the scope of a release.
Specific systems (e.g., monitoring, detection, control, pressure relief, alarms, mitigation) may
limit a release or prevent the failure from occurring. Also, if you are required to analyze alterna-
tive release scenarios (i.e., if your facility is in Program 2 or Program 3), these scenarios are gen-
erally more realistic than the worst case, and you can offer to provide additional information on
those scenarios.
What does it mean that we could be exposed if we

live/work/shop/go to school X miles away?
(For an accident involving a flammable substance):
The distance means that people who are in that area around the facility could be hurt if the con-
tents of a tank or other vessel exploded. The blast of the explosion could shatter windows and
damage buildings. Injuries would be the result of the force of the explosion and of flying glass
or falling debris.
(For an accident involving a toxic substance):
The distance is based on a concentration of the chemical that you could be exposed to for an
hour without suffering irreversible health effects or other symptoms that would make it difficult
for you to escape. If you are within that distance, you could be exposed to a greater concentra-
tion of the chemical. If you were exposed to higher levels for an extended period of time (10
minutes, 30 minutes, or longer), you could be seriously hurt. However, that does not mean that
you would be. Remember, for worst-case scenarios, the rule requires you to make certain con-
servative assumptions with respect to, for example, wind speed and atmospheric stability.
If the wind speed is higher than that used in the modeling, or if the atmosphere is more unsta-
ble, a chemical release would be dispersed more quickly, the distances would be much smaller
and the exposure times would be shorter. If the question pertains to an alternative release sce-
nario, you probably assumed typical weather conditions in the modeling. Therefore, the actual
impact distance could be shorter or longer, and you should be prepared to acknowledge this
and clearly explain how you chose the conditions for your release scenario.
In general, the possibility of harm depends on the concentration of the chemical you are
exposed to and the length of time you are exposed.

Annex 5
If there is an accident, will everyone within that distance be

hurt? What about property damage?
In general, no. For an explosion, everyone within the circle would certainly feel the blast wave
since it would move in all directions at once. However, while some people within the circle could
be hurt, it is unlikely that everyone would be since some people would probably be in less vul-
nerable locations. Most injuries would probably be due to the effects of flying glass, falling
debris, or impact with nearby objects.
Two types of chemicals may be modeled—toxics and flammables. Releases of flammables do
not usually lead to explosions; released flammables are more likely to disperse without igniting.
If the released flammable does ignite, a fire is more likely than an explosion, and fires are usu-
ally concentrated at the facility.
For toxic chemicals, whether someone is hurt by a release depends on many factors. First, the
released chemicals would usually move in the direction of the wind (except for some dense
gases, which may be constrained by terrain features to flow in a different direction). Generally,
only people downwind from the facility would be at risk of exposure if a release occurred, and
this is normally only a part of the population inside the circle. If the wind speed is moderate, the
chemicals would disperse quickly, and people would be exposed to lower levels of the chemi-
cal. If the release is stopped quickly, they might be exposed for a very short time period, which
is less likely to cause injury. However, if the wind speed is low or the release continues for a long
time, exposure levels will be higher and more dangerous. The population at risk would be a larg-
er proportion of the total population inside the circle. You should be prepared to discuss both
possibilities.
Generally, it is the people who are closest to the facility—within a half mile or less—who would
face the greatest danger if an accident occurred.
Damage to property and the environment will depend on the type of chemical released. In an
explosion, environmental impacts and property damage may extend beyond the distance at
which injuries could occur. For a vapor release, environmental effects and property damage may
occur as a result of the reactivity or corrosivity of the chemical or toxic contamination.
How sure are you of your distances?

Perhaps the largest single difficulty associated with hazard assessment is that different models
and modeling assumptions will yield somewhat different results. There is no one model or set
of assumptions that will yield “certain” results. Models represent scientists’ best efforts to
account for all the variables involved in an accidental release. While all models are generally
based on the same physical principles, dispersion modeling is not an exact science due to the
limited opportunity for real-world validation of results. No model is perfect, and every model rep-
resents a somewhat different analytical approach. As a result, for a given scenario, people can
use different consequence models and obtain predictions of the distance to the toxic endpoint
that in some situations might vary by a factor of ten. Even using the same model, different input
assumptions can cause wide variations in the predictions. It follows that, when you present a
single predicted value as your best estimate of the predicted distance, others will be able to claim
that the answer ought to be different, perhaps greater, perhaps smaller, depending on the
assumptions used in modeling and the choice of model itself.
You therefore need to recognize that your predicted distance lies within a considerable band of
uncertainty, and to communicate this fact to those who have an interest in your results. A neigh-
boring facility handling the same covered substances as you do may have come up with a dif-
ferent result for the same scenario for these reasons.

Annex 5
If you use EPA’s RMP Guidance for Offsite Consequence Analysis or one of the industry-specific
guidance documents that EPA has developed, you will be able to address the issue of uncertain-
ty by stating that the results you have generated are conservative (that is they are likely to over-
estimate distances). However, if you use other models, you will have to provide your own assess-
ment of where your specific prediction lies within the plausible range of uncertainties.
Why do you need to store so much on-site?

If you have not previously considered the feasibility of reducing the quantity, you should do so
when you develop your risk management program. Many companies have cited public safety
concerns as a reason for reducing the quantities of hazardous chemicals stored on-site or for
switching to non-hazardous substitutes. If you have evaluated your process and determined that
you need a certain volume to maintain your operations, you should explain this fact to the pub-
lic in a forthright manner. As appropriate, you should also discuss any alternatives, such as reduc-
ing storage quantities and scheduling more frequent deliveries. Perhaps these options are feasi-
ble—if so, you should consider implementing them; if not, explain why you consider these alter-
natives to be unacceptable. For example, in some situations, more frequent deliveries would
mean more trucks carrying the substance through the community on a regular basis and a
greater opportunity for smaller-scale releases because of more frequent loading and unloading.
What are you doing to prevent releases?

If you have rigorously implemented your risk management program, this question will be your
chance, if you have not already done so, to tell the community about your prevention activities,
the safe design features of your operations, the specific activities that you are performing such
as training, operating procedures, maintenance, etc., and any industry codes or standards you
use to operate safely. If you have installed new equipment or safety systems, upgraded training,
or had outside experts review your site for safety (e.g., insurance inspectors), you could offer to
share the results. You may also want to mention state or federal rules you comply with.
What are you doing to prepare for releases?

For such questions, you will need to talk about any coordination that you have done with the
local fire department, LEPC, or mutual aid groups. Such coordination may include activities such
as defining an incident command structure, developing notification protocols, conducting
response training and exercises, developing mutual aid agreements, and evaluating public alert
systems. This description is particularly important if your employees are not designated or
trained to respond to releases of regulated substances.
If your employees will be involved in a response, you should describe your emergency response
plan and the emergency response resources available at the facility (e.g., equipment, personnel),
as well as through response contractors, if appropriate. You also may want to indicate the types
of events for which such resources are applicable. Finally, indicate your schedule for internal
emergency response training and drills and exercises and discuss the results of the latest rele-
vant drill or exercise, including problems found and actions taken to address them.

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Do you need to use this chemical?

Again, if you have not yet considered the feasibility of switching to a non-hazardous substitute,
you should do so when you develop your risk management program. Assuming that there is no
substitute, you should describe why the chemical is critical to what you produce and explain
what you do to handle it safely. If there are substitutes available, you should describe how you
have evaluated such options.
Why are your distances different from the distances in the EPA
lookup tables?
If you did your own modeling, this question may come up. You should be ready to explain in a
general way how your model works and why it produces different results. EPA allows using
other models (as long as certain parameters and conditions specified by the rule are met)
because it realizes that EPA lookup table results will not necessarily reflect all site-specific condi-
tions.
In addition, although all models are generally based on the same physical principles, dispersion
modeling is not an exact science due to the limited opportunity for real-world validation of the
results.
Thus, the method by which different models combine the basic factors such as wind speed and
atmospheric stability can result in distances that readily vary by a factor of two (e.g., five miles
versus ten miles). The introduction of site-specific factors can produce additional differences. EPA
recognizes that different models will produce differing predictions of the distance to an end-
point, especially for releases of toxic substances. The Agency has provided a discussion of the
uncertainties associated with the model it has adopted for the OCA Guidance. You need to
understand that the distances produced by another model lie within a band of uncertainty and
be able to demonstrate and communicate this fact to those who are reviewing your results.
How likely are the worst-case and alternative release

scenarios?
It is generally not possible to provide accurate numerical estimates of how likely these scenarios
are. EPA has stated that providing such numbers for accident scenarios rarely is feasible because
the data needed (e.g., on rates for equipment failure and human error) are not usually available.
Even when data are available, there are large uncertainties in applying the data because each
facility’s situation is unique.
In general, the risk of the worst-case scenario is low. Although catastrophic vessel failures have
occurred, they are rare events. Combining them with worst-case weather conditions makes the
overall scenario even less likely. This does not mean that such events cannot or will not happen,
however.
For the alternative scenario, the likelihood of the release is greater and will depend, in part, on
the scenario you chose. If you selected a scenario based on your accident history or industry acci-
dent history, you should explain this to the public. You should also discuss any steps you are tak-
ing to prevent such an accident from recurring.

Annex 5
Is the worst-case release you reported really the worst

accident you can have?
The answer to this question will depend on the type of facility you have and how you handle
chemicals. EPA defined a specific scenario (failure of the single largest vessel) to provide a com-
mon basis of comparison among facilities nationwide. So, if you have only one vessel, EPA’s
worst case is likely to be the worst event you could have.
On the other hand, if you have a process which involves multiple co-located or interconnected
vessels, it is possible that you could have an accident more severe than EPA’s worst-case scenario.
If credible scenarios exist that could be more serious (in terms of quantities released or conse-
quences) than the EPA worst-case scenario, you should be ready to discuss them. For example,
if you store chemicals in small containers such as 55-gallon drums, the EPA-defined worst-case
release scenario may involve a limited quantity, but a fire or explosion at the facility could release
larger quantities if multiple containers are involved. In this case, you should be ready to frankly
discuss such a scenario with the public.
If you take precautions to prevent such scenarios from occurring, you should explain these pre-
cautions also. If an accidental release is more likely to involve multiple drums than a single drum
as a result, for example, of the drums being stored closely together, then you must select such
a scenario as your alternative release scenario so that information on this scenario is available in
your RMP.
Chemical manufacturers may want to talk about releases that could result from runaway reac-
tions that could continue for several hours. This type of event could result in longer exposure
times.
What about the accident at the (name of similar facility)

that happened last month?
This question highlights an important point: you need to be aware of events in your industry
(e.g., accidents, new safety measures) for two reasons. First, your performance likely will be
compared to that of your competitors. Second, learning about the circumstances and causes of
accidents at other facilities like yours can help you prevent such accidents from occurring at your
facility.
You should be familiar with accidents that happen at facilities similar to yours, and you should
have evaluated whether your facility is at risk for similar accidents. You should take the appro-
priate measures to prevent the accident from occurring and be prepared to describe these
actions. If your facility has experienced a similar release in the past, this information may be doc-
umented in your accident history or other publicly available records, depending on the date and
nature of the incident, the quantity released, and other factors.
If you have already taken steps specifically designed to address this type of accident, whether as
a result of this accident, a prior accident at your facility, or other internal decision-making, you
should describe these efforts. If, based on your evaluation, you determine that the accident
could not occur at your facility, you should discuss the pertinent differences between the two
facilities and explain why you believe those differences should prevent the accident from occur-
ring at your facility.

Annex 5
What actions have you taken to involve the community in

your accident prevention and emergency planning efforts?
If you have not actively involved the community in accident prevention and emergency planning
in the past, you should acknowledge this as an area where you could improve and start doing
so as you develop your risk management program. First, you may want to begin participating
in the LEPC and regional mutual aid organizations if you aren’t doing so already. Other oppor-
tunities for community involvement are fire safety coordination activities with the local fire
department, joint training and exercises with local public and private sector response personnel,
the establishment of green fields between the facility and the community, and similar efforts.
When discussing accident prevention and emergency planning with the community, you should
indicate any national programs in which you participate, such as the Chemical Manufacturers
Association’s Responsible Care program or Community Awareness and Emergency Response
program or OSHA’s Voluntary Protection Program. If fully implemented, these programs can help
improve the safety of the facility and the community. You may have future plans to participate
in areas described previously or have new initiatives associated with the risk management pro-
gram. Be sure you ask what else the community would like you to do and explain how you will
do it.
Can we see the documentation you keep on site?

If the requested information is not confidential business information, EPA encourages you to
make it available to the public. Although you are not required to provide this information to the
public, refusing to provide it simply because you are not compelled to is not the best approach.
If you decide not to provide any or most of this material, you should have good reasons for not
doing so and be prepared to explain these reasons to the public. Simply taking a defensive posi-
tion or referring to the extent of your legal obligations is likely to threaten the effectiveness of
your interaction with the community. Offer as much information as possible to the public; if par-
ticular documents would reveal proprietary information, try to provide a redacted copy, summa-
ry, or some other form that answers the community’s concerns. You may want to work with
your LEPC on this issue. You should also be aware that information that EPA or the implement-
ing agency obtains as part of an inspection or investigation conducted under section 114 of the
Clean Air Act would be available to the public under section 114(c) of the Act to the extent it
does not reveal confidential business information.
11.3 Communication Activities and Techniques

Although this section is most applicable to larger companies, small businesses may want to
review it and use some of the ideas to expand their communications with the public. To prepare
for effective communication with the community, you should:
• Adopt an organizational policy that includes basic risk communication principles
(see Exhibit 11-1).
• Assign responsibilities and resources to implement the policy.
• Plan to use “best communication practices.”

Annex 5
Adopt an Organizational Communications Policy

An organizational policy will support communication with the public on your RMP and make it
an integral part of management practices. Otherwise, breakdowns are likely to occur, which
could cause mistrust, hostility and conflicts.
A policy helps to establish communication as a normal organizational function and to present it
as an opportunity rather than a burden or threat. The policy can be incorporated in an organi-
zation’s policies, an approach taken by many companies who belong to the Responsible Care
program of the Chemical Manufacturers Association (CMA). These companies have adopted
CMA’s Codes of Management Practices, which contain risk communication principles and prac-
tices.
Remember that what you communicate is more important than the type of communication pol-
icy or program you use, and what you actually do to maintain a safe facility is more important
than anything you say. Your company’s safety and prevention steps in your risk management
program should serve as the core elements of any risk communication program.
Assign Responsibilities and Resources

A policy is only a paper promise until it is regularly and effectively implemented. Thus, you should
follow up your communication policy by
(1) having top management participate at the outset and at key points throughout the com-
munication process, and
(2) assigning communication responsibilities within your organization and providing the nec-
essary resources.
Experience has demonstrated that assigning responsibility to knowledgeable managers, plant
engineers, and staff and encouraging participation by employees (most of whom are likely to
be community residents) is a good communications practice. Delegating communication func-
tions to outside technical consultants, attorneys, and public relations specialists has repeatedly
failed to impress the community and even tends to incur mistrust. (However, if you hired a firm
with acknowledged expertise in dispersion modeling, you may want them on hand to help
respond to technical questions.)
Communications staff will need work time and resources to prepare presentation materials, hold
meetings with interested persons in the community, and do other work necessary to respond to
questions and concerns and maintain ongoing dialogue. A training program in communication
skills and incentives for good performance also may be advisable.
Organizations have a legitimate interest in preventing disclosure of confidential business infor-
mation or statements that inadvertently and unfairly harm the organization or its employees.
Thus, you should assure that your risk communication staff is instructed on how to deal with
situations that pose these problems. This may mean that you have an internal procedure
enabling your staff to bring such situations to top management and legal counsel for quick res-
olution, keeping in mind that unduly defensive or legalistic responses that result in restricting the
amount of information that is provided can damage or destroy the risk communication process.

Annex 5
Your communication staff may find the following steps helpful in addressing the priority issues
in the communication process:
Prior to RMP Submittal
∆ Enlist employee support for, and involvement in, the communication process.
∆ Build on work you have done with your LEPC, fire department, and local officials, and
gain their insights.
∆ Incorporate technical expertise, management commitment, and employee involvement
in the risk communication process.
∆ Use your RMP’s executive summary to begin the dialogue with the community; be sure
you have taken all of the steps you present.
∆ Taking a community perspective, identify which data elements need to be clarified, inter-
preted, or amplified, and which are most likely to raise community concerns; then com-
pile the information needed to respond and determine the most understandable meth-
ods (e.g., use of graphics) for presenting the information.
At Submittal
∆ Review the RMP to assure that you are familiar with its data elements and how they were
developed. In particular, review the hazard assessment, prevention, and response pro-
gram features, as well as documentation of the methods, data, and assumptions used,
especially if an outside consultant performed the analyses and developed these materi-
als. You have certified their accuracy and your spokesperson should know them intimate-
ly, as they reflect your plan.
∆ Review your performance in implementing the prevention and response programs and
prepare to discuss problems identified and actions taken.
∆ Review your performance in investigating accidents and prepare to discuss any corrective
actions that followed.
Other Steps
∆ Identify the most likely concerns about risks identified in the RMP but not fully addressed,
consult with management and safety engineering, and determine additional measures
the organization will take to resolve these concerns.
∆ Avoid misrepresentations and minimize the roles of public relations specialists.
∆ Identify “best communication practices” (as described in the next section) and plan how
to use them.
Use “Best Communication Practices”

Many facilities already have gained considerable experience in communicating with the public.
Lessons from their experiences are described below. However, the value of these best practices
and your credibility will depend on your facility’s possession and ongoing demonstration of cer-
tain essential qualities:
• Top management commitment (e.g., owner and facility manager) to improving safety
• Honesty, openness, and concern for the community
• Respect for public concerns and perceptions
• Commitment to maintaining a dialogue with all sectors of the community, to learning from
this dialogue, and to being prepared to change your practices to make your facility more
safe

Annex 5
• Commitment to continuous improvement through internal procedures for evaluating inci-

dents and promoting organizational learning
• Knowledge of safety issues and safety management methods
• Good working relationships with the LEPC, fire department, and other local officials
• Active support for the LEPC and related activities
• Employee support and commitment
• Continuation of commitment despite potential public hostility or mistrust
Another note:
Because each facility and community involves a unique combination of factors, the practices
used to achieve good risk communication in one case do not necessarily ensure the same qual-
ity result when used in another case. Therefore, while it is advisable for you to review such expe-
rience to identify “best communication practices,” you should carefully evaluate such practices
to determine if they can be adapted to fit your unique circumstances. For example, if your facil-
ity is in the middle of an urban area, you probably will use different approaches than you would
use if it were located in an industrial area far from any residential populations. These practices
are complementary approaches to delivering your risk management message and responding
to the concerns of the community.
With these cautions in mind, a number of “best” practices are outlined below for con-
sideration. First, you will want to establish formal channels for information-sharing
and communication with stakeholders. The most basic approaches include the follow-
ing:
• Convene public meetings for discussion and dialogue regarding your risk management pro-
gram and RMP and take steps to have the facility owner or manager and all sectors of the
community participate, including minorities and low-income residents.
• Arrange meetings with local media representatives to facilitate their understanding of your
risk management program and the program summary presented in your RMP.
• Establish a repository of information on safety matters for the LEPC and the public and, if
electronic, provide software for public use. Some organizations also have provided computer
terminals for public use in the community library or fire department.
Other, more resource-intensive activities of this type to consider include the follow-
ing:
• Create and convene focus groups (small working groups) to facilitate dialogue and action
on specific concerns, including technical matters, and take steps to assure that membership
in each group reflects a cross section of the community and includes technically trained per-
sons (e.g., engineers, medical professionals).
• Hold seminars on hypothetical release scenarios, prevention and response programs, appli-
cable standards and industry practices, analytic methods and models (e.g., on dispersion of
airborne releases, health effects of airborne concentrations), and other matters of special
concern or complexity.
• Convene special meetings to foster dialogue and collaborations with the LEPC and the fire
department and to establish a mutual assistance network with other facility managers in the
community or region.
• Establish hot lines for telephone and e-mail communications between interested parties and
your designated risk communication staff and, if feasible, a web site for posting useful infor-
mation.

Annex 5
In all of these efforts, remember to use plain language and commonly understood terms; avoid
the use of acronyms and technical and legal jargon. In addition, depending on your audience,
keep in mind that the preparation of multilingual materials may be useful or even necessary.
Secondly, you may want to initiate or expand programs that more directly involve the
community in your operations and safety programs. Traditional approaches include
the following:
• Arrange facility tours so that members of the public can view operations and discuss safety
procedures with supervisors and employees.
• Schedule drills and simulations of incidents to demonstrate how prevention and response
programs work, with participation by community responders and other organizations (e.g.,
neighboring companies).
• Conduct a “Safety Street”—a community forum generally sponsored by several industries in
a locality, where your representatives present facility safety information, explain risks, and
respond to public questions (see Section 11.4 for a reference to more information on this
program).
• Periodically reaffirm and demonstrate your commitment to safety in accordance with and
beyond regulatory requirements and present data on your safety performance, using appro-
priate benchmarks or measures, in newsletters and by posting the information at your web
site.
• Publicly honor and reward managers and employees who have performed safety responsi-
bilities in superior fashion and citizens who have made important contributions to the dia-
logue on safety.
If community interest is significant, you may also want to consider the following activ-
ities:
• Invite public participation in monitoring implementation of your risk management program
elements.
• Invite public participation in auditing your performance in safety responsibilities, such as
chemical handling and tracking procedures and analysis and follow-up on accidents and
near misses.
• Organize a committee comprised of representatives from the facility, other industry, emer-
gency planning and response organizations, and community groups and chaired by a com-
munity leader to independently evaluate your safety and communication efforts (e.g., a
Community Advisory Panel). You may also want to finance the committee to pay for an
independent engineering consultant to assist with technical issues and learn what can be
done to improve safety, and thereby share control with the community.
Your communication staff should review these examples, consider designing their own activities
as well as joint efforts with other local organizations, and ultimately decide with the communi-
ty on which set of practices are feasible and can best create a healthy risk communication
process in your community. Once these decisions are made, you may want to integrate the cho-
sen set of practices in an overall communication program for your facility, transform some into
standard procedures, and monitor and evaluate them for continuous improvement.

Annex 5
Other Communication Opportunities

By complying with the RMP rule and participating in the communications process with the com-
munity, you should have developed a comprehensive system for preventing, mitigating, and
responding to chemical accidents at your facility. Why not share this knowledge with your staff,
others you do business with (e.g., customers, distributors, contractors), and, perhaps through
industry groups, others in your industry? If you transfer this knowledge to others, you can help
improve their chemical safety management capabilities, enhance public safety beyond your
community, and possibly gain economic benefits for your organization.
11.4 For More Information

Among the numerous publications on risk communication, the following may be particularly
helpful:
• Improving Risk Communication, National Academy Press, Washington, D.C., 1989
• “Safety Street” and other materials on the Kanawha Valley Demonstration Program,
Chemical Manufacturers Association, Arlington, VA
• Community Awareness and Emergency Response Code of Management Practices and
Various Guidance, Chemical Manufacturers Association, Arlington, VA
• Communicating Risks to the Public, R. Kasperson and P. Stallen, eds., Kluwer Publishing Co.,
1991
• “Challenges in Risk and Safety Communication with the Public,” S. Maher, Risk
Management Professionals, Mission Viejo, CA, April 1996
• Primer on Health Risk Communication Principles and Practices, Agency for Toxic Substances
and Disease Registry, on the World Wide Web at atsdr1.atsdr.cdc.gov:8080
• Risk Communication about Chemicals in Your Community: A Manual for Local Officials, US
Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA Hotline
• Risk Communication about Chemicals in Your Community: Facilitator’s Manual and Guide,
US Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA Hotline
• Chemicals, the Press, and the Public, A Journalist’s Guide to Reporting on Chemicals in the
Community, US Environmental Protection Agency, EPA EPCRA/Superfund/RCRA/CAA
Hotline.

Calculation Method for
the Worst-case Scenario:
Excerpts from the EPA Document
“Risk Management Program Guidance for Offsite
Consequence Analysis”
Annex
6 261
Annex 6
Note:
This annex consists of excerpts from the “Risk Management Program Guidance for Offsite
Consequence Analysis” document of the Environmental Protection Agency (EPA 550-B-99- 009,
April 1999). All the references contained in this annex thus pertain to this document.

Annex 6
Purpose of this Guidance
T his document provides guidance on how to conduct the offsite consequence analyses for
Risk Management Programs required under the Clean Air Act (CAA). Section 112(r)(7) of the
CAA directed the U.S. Environmental Protection Agency (EPA) to issue regulations requiring facil-
ities with large quantities of very hazardous chemicals to prepare and implement programs to
prevent the accidental release of those chemicals and to mitigate the consequences of any
releases that do occur. EPA issued that rule,”Chemical Accident Prevention Provisions,” on June
20, 1996. The rule is codified at part 68 of Title 40 of the Code of Federal Regulations (CFR). If
you handle, manufacture, use, or store any of the toxic or flammable substances listed in 40 CFR
68.130 above the specified threshold quantities in a process, you are required to develop and
implement a risk management program under part 68 of 40 CFR. The rule applies to a wide
variety of facilities that handle, manufacture, store, or use toxic substances, including chlorine
and ammonia, and highly flammable substances, such as propane. If you are not sure whether
you are subject to the rule, you should review the rule and Chapters 1 and 2 of EPA’s General
Guidance for Risk Management Programs (40 CFR part 68), available from EPA at
http://www.epa.gov/ceppo/.
If you are subject to the rule, you are required to conduct an offsite consequence analysis to pro-
vide information to the state, local, and federal governments and the public about the poten-
tial consequences of an accidental chemical release. The offsite consequence analysis consists of
two elements:
• A worst-case release scenario, and
• Alternative release scenarios.

Annex 6
3. Release Rates for Toxic Substances
3.1 Release Rates for Toxic Gases

Toxic gases include all regulated toxic substances that are gases at ambient temperature (25ºC,
77ºF), with the exception of gases liquefied by refrigeration under atmospheric pressure and
released into diked areas. For the worst-case consequence analysis, you must assume that a
gaseous release of the total quantity occurs in 10 minutes. You may take passive mitigation
measures (e.g., enclosure) into account in the analysis of the worst-case scenario.
Gases liquefied by refrigeration alone and released into diked areas may be treated as liquids at
their boiling points if they would form a pool upon release that is more than one centimeter
(0.033 foot) in depth. Gases liquefied by refrigeration alone that would form a pool one cen-
timeter (0.033 foot) or less in depth should be treated as gases. Modeling shows that the evap-
oration rate from such a pool would be equal to or greater than the rate for a toxic gas, which
is assumed to be released over 10 minutes; therefore, treating liquefied refrigerated gases as
gases rather than liquids in such cases is reasonable. You may consider passive mitigation for
gaseous releases and releases of gases liquefied by refrigeration.
3.1.1 Unmitigated Releases of Toxic Gas
If no passive mitigation system is in place, estimate the release rate for the release over a 10-
minute period of the largest quantity resulting from a pipe or vessel failure, as required by the
rule (40 CFR 68.25(c)). For a release from a vessel, calculate the release rate as follows:
Equation 3-1: QR = QS
10
where:
QR = Release rate (pounds per minute)
QS = Quantity released (pounds)
Example 1: Gas Release (Diborane)

You have a tank containing 2,500 pounds of diborane gas.
Assuming the total quantity in the tank is released over a 10-minute period, the release rate
(QR), from Equation 3-1, is:
QR = 2,500 pounds/10 minutes = 250 pounds per minute

Annex 6
3.1.2 Releases of Toxic Gas in Enclosed Space

If a gas is released in an enclosure such as a building or shed, the release rate to the outside air
may be lessened considerably. The dynamics of this type of release are complex; however, you
may use the simplified method presented here to estimate an approximate release rate to the
outside air from a release in an enclosed space. The mitigation factor (i.e., 55 percent) present-
ed in this method assumes that the release occurs in a fully enclosed, non-airtight space that is
directly adjacent to the outside air. If you are modeling a release in an interior room that is
enclosed within a building, a smaller factor (i.e., more mitigation) may be appropriate. On the
other hand, a larger factor (i.e., less mitigation) should be used for a space that has doors or
windows that could be open during a release. If any of these special circumstances apply to your
site, you may want to consider performing site-specific modeling to determine the appropriate
amount of passive mitigation. In addition, you should not incorporate the passive mitigation
effect of building enclosures into your modeling if you have reason to believe the enclosure
would not withstand the force of the release or if the chemical is handled outside the building
(e.g., moved from one building to another building).
For the worst case, assume as before that the largest quantity resulting from a pipe or vessel
failure is released over a 10-minute period. Determine the unmitigated worst-case scenario
release rate of the gas as the quantity released divided by 10 (Equation 3-1). The release rate
from the building will be approximately 55 percent of the worst-case scenario release rate (see
Appendix D, Section D.1.2 for the derivation of this factor). Estimate the mitigated release rate
as follows:
Equation 3-2: QR = QS x 0.55

10
where:
0.55 = Mitigation factor (discussed in Appendix D, Section D.1.2)
Example 2: Gas Release in Enclosure (Diborane)

Suppose the diborane gas from Example 1 is released inside a building at the rate of 250
pounds per minute.
The mitigated release to the outside air from the building would be:
QR = 250 pounds/minute x 0.55 = 138 pounds per minute
3.1.3 Releases of Liquefied Refrigerated Toxic Gas in Diked Area
If you have a toxic gas that is liquefied by refrigeration alone, and it will be released into an area
where it will be contained by dikes to form a pool more than one centimeter (0.033 foot) in
depth, you may carry out the worst-case analysis assuming evaporation from a liquid pool at the
boiling point of the liquid. If your gas liquefied by refrigeration would form a pool one centime-
ter (0.033 foot) or less in depth, use the methods described in Section 3.1.1 or 3.1.2 above for
the analysis.
For a release in a diked area, first compare the diked area to the maximum area of the pool that
could be formed. You can use Equation 3-6 in Section 3.2.3 to estimate the maximum size of
the pool. Density factors (DF), needed for Equation 3-6, for toxic gases at their boiling points are
listed in Exhibit B-1 of Appendix B. If the pool formed by the released liquid would be smaller
than the diked area, assume a 10-minute gaseous release, and estimate the release rate as
described in Section 3.1.1.

Annex 6
If the dikes prevent the liquid from spreading out to form a pool of maximum size (one centime-
ter in depth), you may use the method described in Section 3.2.3 for mitigated liquid releases
to estimate a release rate from a pool at the boiling point of the released substance. Use
Equation 3-8 in Section 3.2.3 for the release rate. The Liquid Factor Boiling (LFB) for each toxic
gas, needed to use Equation 3-8, is listed in Exhibit B-1 of Appendix B. See the example release
rate estimation below.
After you have estimated the release rate, estimate the duration of the vapor release from the
pool (the time it will take for the pool to evaporate completely) by dividing the total quantity
spilled by the release rate. You need to know the duration of release to choose the appropriate
reference table of distances to estimate the consequence distance, as discussed in Section 4.
(You do not need to consider the duration of the release for chlorine or sulfur dioxide, liquefied
by refrigeration alone.
Only one reference table of distances is provided for worst-case releases of each of these sub-
stances, and these tables may be used regardless of the release duration. The principal reason
for making no distinction between 10-minute and longer releases for the chemical-specific
tables is that the differences between the two are small relative to the uncertainties that have
been identified.)
Example 3: Mitigated Release of Gases Liquefied by Refrigeration (Chlorine)
You have a refrigerated tank containing 50,000 pounds of liquid chlorine at ambient pressure.
A diked area around the chlorine tank of 275 square feet is sufficient to hold all of the spilled
liquid chlorine.
Once the liquid spills into the dike, it is then assumed to evaporate at its boiling point (-29ºF).
The evaporation rate at the boiling point is determined from Equation 3-8.
For the calculation, wind speed is assumed to be 1.5 meters per second and the wind speed
factor is 1.4, LFB for chlorine (from Exhibit B-1) is 0.19, and A is 275 square feet.
The release rate is:
QR = 1.4 x 0.19 x 275 = 73 pounds per minute
The duration of the release does not need to be considered for chlorine.
3.1.4 Assessment of Release Consequences of Toxic Gases
This guide makes available to establishments tables that give the impact radii for worst-case sce-
narios, for neutral/light (approximately the same density as air) or dense behaving gases and
vapors, as well as for rural or urban topographies. These tables have been developed by assum-
ing wind speeds of 1.5 meters per second and an atmospheric stability of F. To be able to use
these tables, the establishment must know the release rates of the worst-case scenario, as cal-
culated in the first part of this chapter. As for dealing with pools of gases liquefied by refrigera-
tion only, contained in diked areas (excluding chlorine and sulfur dioxide), the establishment
must also know the duration of the release in the atmosphere. Moreover, the establishment
must also know the appropriate toxicity thresholds (see Exhibit B-1), as well as the physical
behavior of the gas or vapor (i.e., neutral/light or dense behavior).
The guide provides reference tables (see Reference Tables 1 to 8) for release durations of 10 min-
utes or 60 minutes for dense or neutral/light behaving gases in rural or urban topography con-
ditions. These reference tables differentiate between durations of 10 minutes and less and those
of 10 minutes and more. The establishment should use the 10-minute tables if the duration of
the release is 10 minutes or less, and use the 60-minute tables if the duration of the release
exceeds 10 minutes. To evaluate the worst-case scenario for all toxic gas leaks (i.e., gases stored
at atmospheric pressure, under pressure, liquefied by pressure or liquefied by refrigeration, but
not contained in a diked area), a release duration of 10 minutes must be assumed.

Annex 6
The guide also provides four specific reference tables for anhydrous ammonia or ammonia liq-
uefied under pressure, non-liquefied ammonia, ammonia liquefied by refrigeration or aqueous
ammonia, as well as for chlorine and sulfur dioxide (anhydride) (see Reference Tables 9 to 12).
It should be pointed out that these tables do not take into account the duration of the release.
3.2 Release Rates for Toxic Liquids

For the worst-case analysis, the release rate to air for toxic liquids is assumed to be the rate of
evaporation from the pool formed by the released liquid. This section provides methods to esti-
mate the evaporation rate. Assume the total quantity in a vessel or the maximum quantity from
pipes is released into the pool. Passive mitigation measures (e.g., dikes) may be considered in
determining the area of the pool and the release rate. To estimate the consequence distance
using this guidance, you must estimate how long it will take for the pool to evaporate (the dura-
tion of the release), as well as the release rate, as discussed below.
The rule (40 CFR 68.22(g)) requires you to assume that liquids (other than gases liquefied by
refrigeration) are released at the highest maximum daily temperature for the previous three
years or at process temperature, whichever is higher. This chapter provides methods to estimate
the release rate at 25ºC (77ºF) or at the boiling point, and also provides a method to correct the
release rate at 25ºC for releases at temperatures between 25ºC and 50ºC.
The calculation methods provided in this section apply to substances that are liquids under ambi-
ent conditions or gases liquefied by refrigeration alone that are released to form pools deeper
than one centimeter (see Section 3.1.3 above). You must treat gases liquefied under other con-
ditions (under pressure or a combination of pressure and refrigeration) or gases liquefied by
refrigeration alone that would form pools one centimeter or less in depth upon release as gas
rather than liquid releases (see Sections 3.1.1 and 3.1.2 above).
3.2.1 Releases of Toxic Liquids from Pipes
To consider a liquid release from a broken pipe, estimate the maximum quantity that could be
released assuming that the pipe is full of liquid. To estimate the quantity in the pipe, you need
to know the length of the pipe (in feet) and cross-sectional area of the pipe (in square feet). Note
also that liquid may be released from both directions at a pipe shear (in both the direction of
operational flow and the reverse direction, depending on the location of the shear). Therefore,
the length would be the full length of pipe carrying the liquid on the facility grounds. Then, the
volume of the liquid in the pipe (in cubic feet) is the length of the pipe times the cross-section-
al area. The quantity in the pipe (in pounds) is the volume divided by the Density Factor (DF)
times 0.033. (DF values are listed in Appendix B, Exhibit B-2. Density in pounds per cubic foot is
equal to 1/(DF times 0.033).) Assume the estimated quantity (in pounds) is released into a pool
and use the method and equations described below in Section 3.2.2 (unmitigated releases) or
3.2.3 (releases with passive mitigation) to determine the evaporation rate of the liquid from the
pool.
3.2.2 Unmitigated Releases of Toxic Liquids
If no passive mitigation measures are in place, the liquid is assumed to form a pool one centime-
ter (0.39 inch or 0.033 foot) deep instantaneously. You may calculate the release rate to air from
the pool (the evaporation rate) as discussed below for releases at ambient or elevated temper-
ature.

Annex 6
Ambient Temperature
If the liquid is always at ambient temperature, find the Liquid Factor Ambient (LFA) and the
Density Factor (DF) in Exhibit B-2 of Appendix B. The LFA and DF apply to liquids at 25ºC; if your
ambient temperature is between 25ºC and 50ºC, you may use the method described here and
then apply a Temperature Correction Factor (TCF), as discussed in Section 3.2.5 below, to cor-
rect the calculated release rate.
Calculate the release rate of the liquid at 25ºC from the following equation:
Equation 3-3: QR = QS x 1.4 x LFA x DF

where:
1.4 = Wind speed factor = 1.50.78, where 1.5 meters per second
(3.4 miles per hour) is the wind speed for the worst case
LFA = Liquid Factor Ambient
DF = Density Factor
Example 4: Unmitigated Liquid Release at Ambient Temperature (Acrylonitrile)

You have a tank containing 20,000 pounds of acrylonitrile at ambient temperature.
The total quantity in the tank is spilled onto the ground in an undiked area, forming a pool.
Assume the pool spreads out to a depth of one centimeter. The release rate from the pool
(QR) is calculated from Equation 3-3.
For the calculation, the wind speed is assumed to be 1.5 meters per second and the wind
speed factor is 1.4.
From Exhibit B-2, Appendix B, LFA for acrylonitrile is 0.018 and DF is 0.61.
Then:
QR = 20,000 x 1.4 x 0.018 x 0.61 = 307 pounds per minute
The duration of the release (from Equation 3-5) would be:
t = 20,000 pounds/307 pounds per minute = 65 minutes
Elevated Temperature
If the liquid is at an elevated temperature (above 50ºC or at or close to the boiling point), find
the Liquid Factor Boiling (LFB) and the Density Factor (DF) in Exhibit B-2 of Appendix B (see
Appendix D, Section D.2.2, for the derivation of these factors). For temperatures up to 50ºC,
you may use the method above for ambient temperature and apply the Temperature Correction
Factors, as discussed in Section 3.2.5. If the temperature is above 50ºC, or the liquid is at or close
to its boiling point, or no Temperature Correction Factors are available for your liquid, calculate
the release rate of the liquid from the following equation:
Equation 3-4: QR = QS x 1.4 x LFB x DF
where:
LFB = Liquid Factor Boiling
DF = Density Factor

Annex 6
Example 5: Unmitigated Release at Elevated Temperature (Acrylonitrile)

You have a tank containing 20,000 pounds of acrylonitrile at an elevated temperature.
The total quantity in the tank is spilled onto the ground in an undiked area, forming a pool.
Assume the pool spreads out to a depth of one centimeter.
The release rate from the pool is calculated from Equation 3-4. For the calculation, the wind
speed factor for 1.5 meters per second is 1.4.
From Exhibit B-2, Appendix B, LFB for acrylonitrile is 0.11 and DF is 0.61.
Then:
QR = 20,000 x 1.4 x 0.11 x 0.61 = 1,880 pounds per minute
t = 20,000 pounds/1880 pounds per minute = 11 minutes
Duration of Release
After you have estimated a release rate as described above, determine the duration of the vapor
release from the pool (the time it will take for the liquid pool to evaporate completely). If you
calculate a corrected release rate for liquids above 25ºC, use the corrected release rate, estimat-
ed as discussed in Section 3.2.5 below, to estimate the release duration.
To estimate the time in minutes, divide the total quantity released (in pounds) by the release rate
(in pounds per minute) as follows:
Equation 3-5: t = QS
QR
where:
t = Duration of the release (minutes)
(use release rate corrected for temperature, QRc, if appropriate)
You will use the duration of the vapor release from the pool to decide which table is appropri-
ate for estimating distance, as discussed in Chapter 4 below.
3.2.3 Releases of Toxic Liquids with Passive Mitigation
Diked Areas
If the toxic liquid will be released into an area where it will be contained by dikes, compare the
diked area to the maximum area of the pool that could be formed; the smaller of the two areas
should be used in determination of the evaporation rate. The maximum area of the pool (assum-
ing a depth of one centimeter) is:
Equation 3-6: A= QS x DF
where:
A = Maximum area of pool (square feet) for depth of one centimeter
DF = Density Factor (listed in Exhibit B-2, Appendix B)
Maximum Area Smaller than Diked Area
If the maximum area of the pool is smaller than the diked area, calculate the release rate as
described for “no mitigation” above.

Annex 6
Diked Area Smaller than Maximum Area

If the diked area is smaller than the maximum pool area, go to Exhibit B-2 in Appendix B to find
the Liquid Factor Ambient (LFA), if the liquid is at ambient temperature, or the Liquid Factor
Boiling (LFB), if the liquid is at an elevated temperature. For liquids at temperatures between
25ºC and 50ºC, you may use the method described here and then apply Temperature
Correction Factor (TCF), as discussed in Section 3.2.5 below, to correct the calculated release
rate.
For gases liquefied by refrigeration alone, use LFB from Exhibit B-1.
Calculate the release rate from the diked area as follows for liquids at ambient temperature:
Equation 3-7: QR = 1.4 x LFA x A
or, for liquids at elevated temperature or for gases liquefied by refrigeration alone:
Equation 3-8: QR = 1.4 x LFB x A
where:
LFA = Liquid Factor Ambient (listed in Exhibit B-2, Appendix B)
LFB = Liquid Factor Boiling (listed in Exhibit B-1 (for liquefied gases)
or B-2 (for liquids), Appendix B)
A = Diked area (square feet)
Potential Overflow of Diked Area
In case of a large liquid spill, you also need to consider whether the liquid could overflow the
diked area.
Follow these steps:
• Determine the volume of the diked area in cubic feet from surface area times depth or
length times width times depth (in feet).
• Determine the volume of liquid spilled in cubic feet from QS x DF x 0.033
(DF x 0.033 is equal to 1/density in pounds per cubic foot).
• Compare the volume of the diked area to the volume of liquid spilled. If the volume of
liquid is greater than the volume of the diked area:
1 Subtract the volume of the diked area from the total volume spilled to determine the
volume that might overflow the diked area.
2 Estimate the maximum size of the pool formed by the overflowing liquid (in square
feet) by dividing the overflow volume (in cubic feet) by 0.033 (the depth of the pool in
feet).
3 Add the surface area of the diked area and the area of the pool formed by the over-
flow to estimate the total pool area (A).
4 Estimate the evaporation rate from Equation 3-7 or 3-8 above.
After you have estimated the release rate, estimate the duration of the vapor release from the
pool by dividing the total quantity spilled by the release rate (Equation 3-5 above).
Example 6: Mitigated Liquid Release at Ambient Temperature (Bromine)

You have a tank containing 20,000 pounds of bromine at an ambient temperature of 25ºC.
Assume that the total quantity in the tank is spilled into a square diked area 10 feet by 10
feet (area 100 square feet). The dike walls are four feet high. The area (A) that would be cov-
ered to a depth of 0.033 feet (one centimeter) by the spilled liquid is given by Equation 3-6 as
the quantity released (QS) times the Density Factor (DF).

Annex 6
From Exhibit B-2, Appendix B, DF for bromine is 0.16.

Then:
A = 20,000 x 0.16, or 3,200 square feet
The diked area is smaller than the maximum pool area. The volume of bromine spilled is
20,000 x 0.16 x 0.033, or 106 cubic feet. The spilled liquid would fill the diked area to a
depth of a little more than one foot, well below the top of the wall. You use the diked area
to determine the evaporation rate from Equation 3-7.
For the calculation, wind speed is 1.5 meters per second, the wind speed factor is 1.4, LFA for
bromine (from Exhibit B-2) is 0.073, and A is 100 square feet.
The release rate is:
The maximum duration of the release would be:
t = 20,000 pounds/10 pounds per minute = 2,000 minutes
Other Containment
If the toxic liquid will be contained by other means (e.g., enclosed catch basins or trenches), con-
sider the total quantity that could be spilled and estimate the surface area of the released liquid
that potentially would be exposed to the air. Look at the dimensions of trenches or other areas
where spilled liquids would be exposed to the air to determine the surface area of pools that
could be formed. Use the instructions above to estimate a release rate from the total surface
area.
Releases into Buildings
If the toxic liquid is released inside a building, compare the area of the pool that would be
formed (depending upon floor space or passive mitigation) to the maximum area of the pool
that could be formed (if the liquid is not contained); the smaller of the two areas should be used
in determining the evaporation rate. The maximum area of the pool is determined as described
above for releases into diked areas, using Equation 3-6.
If the toxic liquid would spread to cover the building floor, you determine the area of the build-
ing floor as:
Equation 3-9: A = L x W
where:
A = Area (square feet)
L = Length (feet)
W = Width (feet)
If there are obstacles such as dikes inside the building, determine the size of the pool that would
be formed based on the area defined by the dikes or other obstacles.
The evaporation rate is then determined for a worst-case scenario (i.e., wind speed is 1.5 meters
per second (3.4 miles per hour)), using Equation 3-3 or 3-4, if the liquid spreads to its maximum
area, or Equation 3-7 or 3-8, if the pool area is smaller than the maximum. The maximum rate
of evaporated liquid exiting the building is taken to be 10 percent of the calculated worst-case
scenario evaporation rate (see Appendix D, Section D.2.4 for the derivation of this factor), as fol-
lows:

Annex 6
Equation 3-10: QRB = 0.1 x QR

where:
QRB = Release rate from building B
QR = Release rate from pool, estimated as discussed above
0.1 = Mitigation factor, discussed in Appendix D, Section D.2.4
Note that the mitigation factor (i.e., 0.1) presented in this method assumes that the release
occurs in a fully enclosed, non-airtight space that is directly adjacent to the outside air. It may
not apply to a release in an interior room that is enclosed within a building, or to a space that
has doors or windows that could be open during a release. In such cases, you may want to con-
sider performing site-specific modeling to determine the appropriate amount of passive mitiga-
tion.
Example 7: Liquid Release Inside Building (Bromine)
Suppose that your tank of bromine from Example 6 is contained inside a storage shed 10 feet
by 10 feet (area 100 square feet). There are no dikes inside the shed. From Example 6, you
see that the area covered by the bromine in an unenclosed space would be 3,200 square
feet. The building area is smaller than the maximum pool area; therefore, the building floor
area should be used to determine the evaporation rate from Equation 3-7.
For the calculation, first determine the worst-case scenario evaporation rate:
The release rate to the outside air of the evaporated liquid leaving the building would then be:
QR = 0.1 x 10 pounds per minute = 1 pound per minute
3.2.4 Mixtures Containing Toxic Liquids
Mixtures containing regulated toxic substances do not have to be considered if the concentra-
tion of the regulated substance in the mixture is below one percent by weight or if you can
demonstrate that the partial vapor pressure of the regulated substances in the mixture is below
10 millimeters of mercury (mm Hg).
Regulated substances present as by-products or impurities would need to be considered if they
are present in concentrations of one percent or greater in quantities above their thresholds, and
their partial vapor pressures are 10 mm Hg or higher. In case of a spill of a liquid mixture con-
taining a regulated toxic substance with partial vapor pressure of 10 mm Hg or higher (with the
exception of common water solutions, discussed in the next section), you have several options
for estimating a release rate:
• Carry out the analysis as described above in Sections 3.2.2 or 3.2.3 using the quantity of the
regulated substance in the mixture and the liquid factor (LFA or LFB) and density factor for the
regulated substance in pure form. This is a simple approach that likely will give conservative
results.
• If you know the partial pressure of the regulated substance in the mixture, you may estimate
a more realistic evaporation rate. An equation for the evaporation rate is given at the end of
the Section B.2 in Appendix B. (See excerpt on next page)
∆ In this case, estimate a pool size for the entire quantity of the mixture, for an unmitigat-
ed release. If you know the density of the mixture, you may use it in estimating the pool
size; otherwise, you may assume the density is the same as the pure regulated substance
(in most cases, this assumption is unlikely to have a large effect on the results).

Annex 6
• You may estimate the partial pressure of the regulated substance in the mixture by the
method described in Section B.2 in Appendix B (see excerpt following) and use the equation
presented there to estimate an evaporation rate. This equation is appropriate to mixtures and
solutions in which the components do not interact with each other. It is probably inappropri-
ate for most water solutions. It is likely to overestimate the partial vapor pressure of regulat-
ed substances in water solutions in which hydrogen bonding may occur (e.g., solutions of
acids or alcohols). As discussed above, use the pool size for the entire quantity of the mixture
for an unmitigated release.
[Excerpted from Section B.2, Appendix B]

To estimate partial pressure for a regulated substance in a mixture or solution, use the follow-
ing steps, based on Raoult’s Law for ideal solutions. Determine the mole fraction of the regu-
lated substance in the mixture. The mole fraction of the regulated substance in the mixture is
the number of moles of the regulated substance in the mixture divided by the total number of
moles of all substances in the mixture. If the molar concentration (moles per liter) of each com-
ponent of the mixture is known, the mole fraction may be determined as follows:
Equation B-1: Mr x Vt
Xr = n
(M x V )
i=1
i t
or (canceling out Vt)
Equation B-2: Mr
Xr = n
i=1
Mi
where:
Xr = Mole fraction of the regulated substance in mixture (unitless)
Mr = Molar concentration of regulated substance in mixture (moles per liter)
Vt = Total volume of mixture (liters)
n = Number of components of the mixture
Mi = Molar concentration of each component of mixture (moles per liter)
For a mixture with three components, this would correspond to
Mr
Equation B-3: Xr =
Mr + M2 + M3
where:
Xr = Mole fraction of the regulated substance in mixture (unitless)
Mr = Molar concentration of regulated substance (first component) in mixture (moles per
liter)
M2 = Molar concentration of second component of mixture (moles per liter)
M3 = Molar concentration of any other components of mixture (moles per liter)

Annex 6
If the weight of each of the components of the mixture is known, the mole fraction of the reg-
ulated substance in the mixture may be calculated as follows:
Equation B-4: Xr = n
{ } Wr
MWr
{ }
i=1
Wi
MWi
where:
Xr = Mole fraction of the regulated substance
Wr = Weight of the regulated substance
MWr = Molecular weight of the regulated substance
Wi = Weight of each component of the mixture
MWi = Molecular weight of each component of the mixture
(Note: Weights can be in any consistent units.)
For a mixture with three components, this corresponds to:
Equation B-5: Xr =
{ } Wr
MWr
{ }{ }{ }
Wr
MWr
+
W1
MW1
+
W2
MW2
where:
Xr = Mole fraction of the regulated substance
Wr = Weight of the regulated substance (first component of the mixture)
W2 = Weight of the second component of the mixture
MW2 = Molecular weight of the second component of the mixture
W3 = Weight of the third component of the mixture
MW3 = Molecular weight of the third component of the mixture
(Note: Weights can be in any consistent units.)
Estimate the partial vapor pressure of the regulated substance in the mixture as follows:
Equation B-6: VPm = Xr x VPp
where:
VPm = Partial vapor pressure of the regulated substance in the mixture
(millimeters of mercury (mm Hg))
Xr = Mole fraction of the regulated substance (unitless)
VPp = Vapor pressure of the regulated substance in pure form at the same temperature as
the mixture (mm Hg) (vapor pressure at 25°C is given in Exhibit B-1, Appendix B)
The evaporation rate for the regulated substance in the mixture is determined as for pure sub-
stances, with VP as the vapor pressure. If the mixture contains more than one regulated toxic
substance, carry out the analysis individually for each of the regulated components.

Annex 6
The release rate equation is:
Equation B-7: QR = 0.0035 x U0.78 x MW2/3 x A x VP

T
where:
QR = Evaporation rate (pounds per minute)
U = Wind speed (meters per second)
MW = Molecular weight (given in Exhibit B-2, Appendix B)
A = Surface area of pool formed by the entire quantity of the mixture (square feet)
(determined as described in 3.2.2)
VP = Vapor pressure (mm Hg) (VPm from Equation B-6 above)
T = Temperature (Kelvin (K); temperature in °C plus 273, or 298 for 25°C)
[end of Excerpted from Section B.2, Appendix B]
Example 8: Mixture Containing Toxic Liquid (Acrylonitrile)

You have a tank containing 50,000 pounds of a mixture of acrylonitrile (a regulated sub-
stance) and N,N-dimethylformamide (not regulated). The weight of each of the components
of the mixture is known (acrylonitrile = 20,000 pounds; N,N-dimethylformamide = 30,000
pounds). The molecular weight of acrylonitrile, from Exhibit B-2, is 53.06, and the molecular
weight of N,N-dimethylformamide is 73.09. Using Equation B-3, Appendix B, calculate the
mole fraction of acrylonitrile in the solution as follows:
Xr = (20,000/53.06)
(20,000/53.06) + (30,000/73.09)
Xr = 377
377 + 410
Xr = 0.48
Estimate the partial vapor pressure of acrylonitrile using Equation B-4 as follows (using the
vapor pressure of acrylonitrile in pure form at 25°C, 108 mm Hg, from Exhibit B-2, Appendix
B):
VPm = 0.48 x 108 = 51.8 mm Hg
Before calculating evaporation rate for acrylonitrile in the mixture, you must determine the
surface area of the pool formed by the entire quantity of the mixture, using Equation 3-6. The
quantity released is 50,000 pounds and the Density Factor for acrylonitrile is 0.61 in Exhibit B-
2; therefore:
A = 50,000 x 0.61 = 30,500 square feet
Now calculate the evaporation rate for acrylonitrile in the mixture from Equation B-5 using the
VPm and A calculated above:
QR = 0.0035 x 1.0 x (53.06)2/3 x 30,500 x 51.8
298
QR = 262 pounds per minute

Annex 6
3.2.5 Release Rate Correction for Toxic Liquids Released at

Temperatures Between 25ºC and 50ºC
If your liquid is at a temperature between 25°C (77°F) and 50°C (122°F), you must use the high-
er temperature for the offsite consequence analysis. You may correct the release rate calculated
for a pool at 25°C to estimate from a pool at the higher temperature using Temperature
Correction Factors (TCF) provided in Appendix B, Exhibit B-4.
Calculate a corrected release rate as follows:
• Calculate the release rate (QR) of the liquid at 25°C (77°F) as described in Section 3.2.2 (for
unmitigated releases) or 3.2.3 (for releases with passive mitigation).
• From Exhibit B-4 in Appendix B:
√ Find your liquid in the left-hand column of the table.
√ Find the temperature closest to your temperature at the top of the table. If your temper-
ature is at the midpoint between two temperatures, go to the higher temperature; oth-
erwise go to the closest temperature (higher or lower than your temperature).
√ Find the TCF for your liquid in the column for the appropriate temperature.
• Estimate a corrected release rate (QRC) by multiplying the estimated release rate by the TCF;
i.e.,
Equation 3-11: QRC = QR x TCF

where:
QRC =Corrected release rate
QR = Release rate calculated for 25°C
TCF = Temperature Correction Factor (from Exhibit B-4, Appendix B)
The derivation of the Temperature Correction Factors is discussed in Appendix D, Section D.2.2.
If you have vapor pressure-temperature data for a liquid not covered in Exhibit B-4, you may cor-
rect the evaporation rate using the method presented in Section D.2.2.
Example 9: Liquid Release at Ambient Temperature Between 25°C and 50°C (Bromine)
Assume the tank containing 20,000 pounds of bromine, from Example 6, is at an ambient
temperature of 35°C (95°F). As in Example 6, the total quantity in the tank is spilled into a
diked enclosure that completely contains the spill. The surface area is 100 square feet. In
Example 6, the release rate (QR) at 25°C was calculated from Equation 3-7 to be 10 pounds
per minute. To adjust the release rate for the temperature of 35°C, you find the Temperature
Correction Factor (TCF) for bromine at 35°C from Exhibit B-4 in Appendix B.
The TCF at this temperature is 1.5; the corrected release rate (QRC) at 35°C, from Equation
3-11, is:
QRC = 10 x 1.5 = 15 pounds per minute
t = 20,000 pounds/15 pounds per minute = 1,300 minutes

Annex 6
3.3 Release Rates for Common Water Solutions of Toxic

Substances and for Oleum
This section presents a simple method of estimating the release rate from spills of water solu-
tions of several substances. Oleum (a solution of sulfur trioxide in sulfuric acid) also is discussed
in this section.
The vapor pressure and evaporation rate of a substance in solution depends on its concentra-
tion in the solution. If a concentrated water solution containing a volatile toxic substance is
spilled, the toxic substance initially will evaporate more quickly than water from the spilled solu-
tion, and the vapor pressure and evaporation rate will decrease as the concentration of the toxic
substance in the solution decreases. At much lower concentrations, water may evaporate more
quickly than the toxic substance. There is one concentration at which the composition of the
solution does not change as evaporation occurs. For most situations of interest, the concentra-
tion exceeds this concentration, and the toxic substance evaporates more quickly than water.
For estimating release rates from solutions, this guidance lists liquid factors (ambient) for sever-
al common water solutions at several concentrations that take into account the decrease in
evaporation rate with decreasing concentration. Exhibit B-3 in Appendix B provides LFA and DF
values for several concentrations of ammonia, formaldehyde, hydrochloric acid, hydrofluoric
acid, and nitric acid in water solution. Factors for oleum are also included in the exhibit. Chlorine
dioxide also may be found in water solutions; however, solutions of chlorine dioxide common-
ly are below one percent concentration. Solutions below one percent concentration do not have
to be considered. Chlorine dioxide, therefore, is not included in Exhibit B-3. These factors may
be used to estimate an average release rate for the listed substances from a pool formed by a
spill of solution. Liquid factors are provided for two different wind speeds, because the wind
speed affects the rate of evaporation.
For the worst case, use the factor for a wind speed of 1.5 meters per second (3.4 miles per
hour). You need to consider only the first 10 minutes of the release for solutions under ambient
conditions in estimating the consequence distance, because the toxic component in a solution
evaporates fastest during the first few minutes of a spill, when its concentration is highest.
Modeling indicates that analysis considering the first 10 minutes of the release gives a good
approximation of the overall consequences of the release. Although the toxic substance will
continue to evaporate from the pool after 10 minutes, the rate of evaporation is so much lower
that it can safely be ignored in estimating the consequence distance. (See Appendix D, Section
D.2.3, for more information.) Estimate release rates as follows:
Ambient Temperature
Unmitigated
If no passive mitigation measures are in place, and the solution is at ambient temperature, find
the LFA at 1.5 meters per second (3.4 miles per hour) and DF for the solution in Appendix B,
Exhibit B-3. Follow the instructions for liquids presented in Section 3.2.2 above to estimate the
release rate of the listed substance in solution. Use the total quantity of the solution as the quan-
tity released (QS) in carrying out the calculation of release rate.
Mitigated
If passive mitigation is in place, and the solution is at ambient temperature, find the LFA at 1.5
meters per second (3.4 miles per hour) in Appendix B, Exhibit B-3, and follow the instructions
for liquids in Section 3.2.3 above. Use the total quantity of the solution to estimate the maxi-
mum pool area for comparison with the diked area.

Annex 6
Example 10: Evaporation Rate for Water Solution at Ambient Temperature

(Hydrochloric Acid)
You have a tank containing 50,000 pounds of 37 percent hydrochloric acid solution, at ambi-
ent temperature. For the worst-case analysis, you assume the entire contents of the tank is
released, forming a pool. The release occurs in a diked area of 9,000 square feet.
From Exhibit B-3, Appendix B, the Density Factor (DF) for 37 percent hydrochloric acid is 0.42.
From Equation 3-6, the maximum area of the pool would be 50,000 times 0.42, or 21,000
square feet. The diked area is smaller; therefore, the diked area should be used in the evapo-
ration rate (release rate) calculation, using Equation 3-7.
For the calculation using Equation 3-7, you need the pool area (9,000 square feet) and the
Liquid Factor Ambient (LFA) for 37 percent hydrochloric acid; you assume a wind speed of 1.5
meters per second, so the wind speed factor is 1.4. From Exhibit B-3, Appendix B, the LFA is
0.0085. From Equation 3-7, the release rate (QR) of hydrogen chloride from the pool is:
QR = 1.4 x 9,000 x 0.0085 = 107 pounds per minute
You do not need to consider the duration of the release, because only the first 10 minutes are
considered.
Known Vapor Pressure
If the solution is at an elevated temperature, the vapor pressure of the regulated substance and
its release rate from the solution will be much higher. This guidance does not include tempera-
ture correction factors for evaporation rates of regulated substances from solutions. If you know
the partial vapor pressure of the toxic substance in solution at the relevant temperature, you can
carry out the calculation of the release rate using the equations in Appendix D, Sections D.2.1
and D.2.2. As for releases of solutions at ambient temperature, you only need to consider the
first 10 minutes of the release, because the evaporation rate of the toxic substance from the
solution will decrease rapidly as its concentration decreases.
Unknown Vapor Pressure
If you do not know the vapor pressure of the substance in solution, as a conservative approach
for the worst-case analysis, use the appropriate instructions, as follows:
Solutions containing substances that are gases under ambient conditions
The list of regulated substances includes several substances that, in their pure form, are gases
under ambient conditions, but that may commonly be found in water solutions. These sub-
stances include ammonia, formaldehyde, hydrogen chloride, and hydrogen fluoride. For a
release of a solution of ammonia, formaldehyde, hydrochloric acid, or hydrofluoric acid above
ambient temperature, if you do not have vapor pressure data for the temperature of interest or
prefer a simpler method, assume the quantity of the pure substance in the solution is released
as a gas over 10 minutes, as discussed in Section 3.1 above. You may determine the amount of
pure substance in the solution from the concentration (e.g., a solution of 37 percent hydrochlo-
ric acid by weight would contain a quantity of hydrogen chloride equal to 0.37 times the total
weight of the solution).

Annex 6
Example 11: Evaporation Rate for Gas in Water Solution at Elevated Temperature
(Hydrochloric Acid)
You have 50,000 pounds of 37 percent hydrochloric acid solution in a high-temperature
process. For the worst-case analysis, you assume the entire contents of the process vessel is
released. In this case, because the solution is at an elevated temperature, you consider the
release of gaseous hydrogen chloride from the hot solution.
The solution would contain 50,000 x 0.37 pounds of hydrogen chloride, or 18,500 pounds.
You assume the entire 18,500 pounds is released over 10 minutes. From Equation 3-1, the
release rate is 18,500 divided by 10, or 1,850 pounds per minute.
Liquids in solution
If you have vapor pressure data for the liquid in solution (including nitric acid in water solution
and sulfur trioxide in oleum) at the temperature of interest, you may use that data to estimate
the release rate, as discussed above. You only need to consider the first 10 minutes of the evap-
oration.
For a release of nitric acid solution at a temperature above ambient, if you do not have vapor
pressure data or prefer to use this simpler method, determine the quantity of pure nitric acid in
the solution from the concentration. Assume the quantity of pure nitric acid is released at an
elevated temperature and estimate a release rate as discussed in Section 3.2 above, using the
LFB. For temperatures between 25°C and 50°C, you may use the LFA and the temperature cor-
rection factors for the pure substance, as described in Section 3.2.5. You do not need to esti-
mate the duration of the release, because you only consider the first 10 minutes.
Similarly, for a release of oleum at an elevated temperature, determine the quantity of free sul-
fur trioxide in the oleum from the concentration and assume the sulfur trioxide is released at an
elevated temperature. Use the LFB or the LFA and temperature correction factors for sulfur tri-
oxide to estimate a release rate as discussed in Section 3.2. You only need to consider the first
10 minutes of the release in your analysis.
For a spill of liquid in solution into a diked area, you would need to consider the total quantity
of solution in determining whether the liquid could overflow the diked area (see the steps in
Section 3.2.3). If you find that the liquid could overflow the dikes, you would need to consider
both the quantity of pure substance remaining inside the diked area and the quantity of pure
substance spilled outside the diked area in carrying out the release rate analysis as discussed in
Section 3.2.3.
Example 12: Evaporation Rate for Liquid in Water Solution at Elevated Temperature
(Nitric Acid)
You have 18,000 pounds of 90 percent nitric acid solution in a high temperature process. The
solution would contain 18,000 x 0.90 pounds of nitric acid, or 16,200 pounds. You assume
16,200 pounds of pure nitric acid is released at an elevated temperature.
For the calculation using Equation 3-4, you need the quantity released (16,200); the Liquid
Factor Boiling (LFB) for nitric acid (0.12 from Exhibit B-2); the Density Factor (DF) for nitric acid
(0.32 from Exhibit B-2); and you assume a wind speed of 1.5 meters per second, so the wind
speed factor is 1.4.
From Equation 3-4, the release rate (QR) of hot nitric acid is:
You do not need to estimate the duration of release, because you only consider the first 10
minutes.

Annex 6
4. Estimation of Worst-case Distance to Toxic

Endpoint
This guidance provides reference tables giving worst-case distances for neutrally buoyant gases
and vapors and for dense gases and vapors for both rural (open) and urban (obstructed) areas.
This chapter describes these reference tables and gives instructions to help you choose the
appropriate table to estimate consequence distances for the worst-case analysis.
Neutrally buoyant gases and vapors have approximately the same density as air, and dense gases
and vapors are heavier than air. Neutrally buoyant and dense gases are dispersed in different
ways when they are released; therefore, modeling was carried out to develop separate refer-
ence tables. These generic reference tables can be used to estimate distances using the speci-
fied toxic endpoint for each substance and the estimated release rate to air. In addition to the
generic tables, chemical-specific reference tables are provided for ammonia, chlorine, and sulfur
dioxide. These chemical-specific tables were developed based on modeling carried out for indus-
try-specific guidance documents. All the tables were developed assuming a wind speed of 1.5
meters per second (3.4 miles per hour) and F stability. To use the reference tables, you need the
worst-case release rates estimated as described in the previous sections. For liquid pool evapo-
ration, you also need the duration of the release. In addition, to use the generic tables, you will
need to determine the appropriate toxic endpoint and whether the gas or vapor is neutrally
buoyant or dense, using the exhibits in Appendix B.
You may interpolate between entries in the reference tables. Generic reference tables are pro-
vided for both 10-minute releases and 60-minute releases. You should use the tables for 10-
minute releases if the duration of your release is 10 minutes or less; use the tables for 60-minute
releases if the duration of your release is more than 10 minutes. For the worst-case analysis, all
releases of toxic gases are assumed to last for 10 minutes. You need to consider the estimated
duration of the release (from Equation 3-5) for evaporation of pools of toxic liquids. For evapo-
ration of water solutions of toxic liquids or of oleum, you should always use the tables for 10-
minute releases.
The generic reference tables of distances (Reference Tables 1-8), which should be used for sub-
stances other than ammonia, chlorine, and sulfur dioxide, are found at the end of Chapter 5.
The generic tables and the conditions for which each table are applicable are described in Exhibit
2. Chemical-specific reference tables of distances (Reference Tables 9-12) follow the generic ref-
erence tables at the end of Chapter 5. Each of these chemical-specific tables includes distances
for both rural and urban topography. These tables are described in Exhibit 3.
Remember that these reference tables provide only rough estimates, not accurate predictions,
of the distances that might be reached under worst-case conditions. In particular, although the
distances in the tables are as great as 25 miles, you should bear in mind that the larger distances
(more than six to ten miles) are very uncertain.

Annex 6
Exhibit 2
Generic Reference Tables of Distances for Worst-case Scenarios
Reference Release Topography Gas or

Table Duration Vapor
Number (minutes) Density
1 10 Rural Neutrally buoyant

3 10 Urban Neutrally buoyant
5 10 Rural Dense
6 60 Rural Dense
7 10 Urban Dense
8 60 Urban Dense
Exhibit 3
Chemical-specific Reference Tables of Distances for Worst-case

Scenarios
Substance Gas or Topography Release Reference

Vapor Duration Table
Density (minutes) Number
Anhydrous Dense Rural 10 9

ammonia Urban
liquefied
under pressure
Non-liquefied Neutrally Rural 10 10
ammonia, buoyant Urban
ammonia liquefied
by refrigeration
or aqueous
ammonia
Chlorine Dense Rural 10 11
Urban
Sulfur dioxide Dense Rural 10 12
(anhydrous) Urban

Annex 6
To use the reference tables of distances, follow these steps:

For Regulated Toxic Substances Other than Ammonia, Chlorine, and Sulfur Dioxide
• Find the toxic endpoint for the substance in Appendix B (Exhibit B-1 for toxic gases or Exhibit
B-2 for toxic liquids).
• Determine whether the table for neutrally buoyant or dense gases and vapors is appropriate
from Appendix B (Exhibit B-1 for toxic gases or Exhibit B-2 for toxic liquids). A toxic gas that is
lighter than air may behave as a dense gas upon release if it is liquefied under pressure,
because the released gas may be mixed with liquid droplets, or if it is cold. Consider the state
of the released gas when you decide which table is appropriate.
• Determine whether the table for rural or urban conditions is appropriate.
∆ Use the rural table if your site is in an open area with few obstructions.
∆ Use the urban table if your site is in an urban or obstructed area. The urban tables are
appropriate if there are many obstructions in the area, even if it is in a remote location,
not in a city.
• Determine whether the 10-minute table or the 60-minute table is appropriate.
∆ Always use the 10-minute table for worst-case releases of toxic gases.
∆ Always use the 10-minute table for worst-case releases of common water solutions
and oleum from evaporating pools, for both ambient and elevated temperatures.
∆ If you estimated the release duration for an evaporating toxic liquid pool to be 10 min-
utes or less, use the 10-minute table.
∆ If you estimated the release duration for an evaporating toxic liquid pool to be more than
10 minutes, use the 60-minute table.
Neutrally Buoyant Gases or Vapors
• If Exhibit B-1 or B-2 indicates the gas or vapor should be considered neutrally buoyant, and
other factors would not cause the gas or vapor to behave as a dense gas, divide the estimat-
ed release rate (pounds per minute) by the toxic endpoint (milligrams per liter).
• Find the range of release rate/toxic endpoint values that includes your calculated release
rate/toxic endpoint in the first column of the appropriate table (Reference Table 1, 2, 3, or 4),
then find the corresponding distance to the right (see Example 13 below).
Dense Gases or Vapors
• If Exhibit B-1 or B-2 or consideration of other relevant factors indicates the substance should
be considered a dense gas or vapor (heavier than air), find the distance in the appropriate table
(Reference Table 5, 6, 7, or 8) as follows:
∆ Find the toxic endpoint closest to that of the substance by reading across the top of the
table. If the endpoint of the substance is halfway between two values on the table,
choose the value on the table that is smaller (to the left). Otherwise, choose the closest
value to the right or the left.
∆ Find the release rate closest to the release rate estimated for the substance at the left
of the table. If the calculated release rate is halfway between two values on the table,
choose the release rate that is larger (farther down on the table). Otherwise, choose
the closest value (up or down on the table).
∆ Read across from the release rate and down from the endpoint to find the distance
corresponding to the toxic endpoint and release rate for your substance.

Annex 6
For Ammonia, Chlorine, or Sulfur Dioxide

• Find the appropriate chemical-specific table for your substance (see the descriptions of
Reference Tables 9-12 in Exhibit 3).
∆ If you have ammonia liquefied by refrigeration alone, you may use Reference Table 10,
even if the duration of the release is greater than 10 minutes.
∆ If you have chlorine or sulfur dioxide liquefied by refrigeration alone, you may use the
chemical-specific reference tables, even if the duration of the release is greater than 10
minutes.
• Determine whether rural or urban topography is applicable to your site.
∆ Use the rural column in the reference table if your site is in an open area with few
obstructions.
∆ Use the urban column if your site is in an urban or obstructed area. The urban column
is appropriate if there are many obstructions in the area, even if it is in a remote loca-
tion, not in a city.
• Estimate the consequence distance as follows:
∆ In the left-hand column of the table, find the release rate closest to your calculated
release rate.
∆ Read the corresponding distance from the appropriate column (urban or rural) to the
right.
The development of Reference Tables 1-8 is discussed in Appendix D, Sections D.4.1 and D.4.2.
The development of Reference Tables 9-12 is discussed in industry-specific risk management
program guidance documents and a backup information document that are cited in Section
D.4.3. If you think the results of the method presented here overstate the potential conse-
quences of a worst-case release at your site, you may choose to use other methods or models
that take additional site-specific factors into account.
Examples 14 and 15 below include the results of modeling using two other models, the Areal
Locations of Hazardous Atmospheres (ALOHA) and the World Bank Hazards Analysis (WHAZ-
AN) systems. These additional results are provided for comparison with the results of the meth-
ods presented in this guidance. The same modeling parameters were used as in the modeling
carried out for development of the reference tables of distances. Appendix D, Section D.4.5,
provides information on the modeling carried out with ALOHA and WHAZAN.
Example 13: Gas Release (Diborane)

In Example 1, you estimated a release rate for diborane gas of 250 pounds per minute. From
Exhibit B-1, the toxic endpoint for diborane is 0.0011 mg/L, and the appropriate reference
table for diborane is a neutrally buoyant gas table. Your facility and the surrounding area have
many buildings, pieces of equipment, and other obstructions; therefore, you assume urban
conditions. The appropriate reference table is Reference Table 3, for a 10-minute release of a
neutrally buoyant gas in an urban area.
The release rate divided by toxic endpoint for this example is 250/0.0011 = 230,000.
From Reference Table 3, release rate divided by toxic endpoint falls between 221,000 and
264,000, corresponding to about 8.1 miles.

Annex 6
Example 14: Gas Release (Ethylene Oxide)

You have a tank containing 10,000 pounds of ethylene oxide, which is a gas under ambient
conditions. Assuming the total quantity in the tank is released over a 10-minute period, the
release rate (QR) from Equation 3-1 is:
QR = 10,000 pounds/10 minutes = 1,000 pounds per minute
From Exhibit B-1, the toxic endpoint for ethylene oxide is 0.09 mg/L, and the appropriate ref-
erence table is the dense gas table. Your facility is in an open, rural area with few obstruc-
tions; therefore, you use the table for rural areas.
Using Reference Table 5 for 10-minute releases of dense gases in rural areas, the toxic end-
point of 0.09 mg/L is closer to 0.1 than 0.075 mg/L. For a release rate of 1,000 pounds per
minute, the distance to 0.1 mg/L is 3.6 miles.
Additional Modeling for Comparison
The ALOHA model gave a distance of 2.2 miles to the endpoint, using the same assumptions.
The WHAZAN model gave a distance of 2.7 miles to the endpoint, using the same assump-
tions and the dense cloud dispersion model.
Example 15: Liquid Evaporation from Pool (Acrylonitrile)

You estimated an evaporation rate of 307 pounds per minute for acrylonitrile from a pool
formed by the release of 20,000 pounds into an undiked area (Example 4). You estimated the
time for evaporation of the pool as 65 minutes. From Exhibit B-2, the toxic endpoint for acry-
lonitrile is 0.076 mg/L, and the appropriate reference table for a worst-case release of acryloni-
trile is the dense gas table. Your facility is in an urban area. You use Reference Table 8 for 60-
minute releases of dense gases in urban areas.
From Reference Table 8, the toxic endpoint closest to 0.076 mg/L is 0.075 mg/L, and the clos-
est release rate to 307 pounds per minute is 250 pounds per minute. Using these values, the
table gives a worst-case consequence distance of 2.9 miles.
The ALOHA model gave a distance of 1.3 miles to the endpoint for a release rate of 307 pounds
per minute, using the same assumptions.
The WHAZAN model gave a distance of 1.0 mile to the endpoint for a release rate of 307
pounds per minute, using the same assumptions and the dense cloud dispersion model.

Annex 6
5. Estimation of Distance to Overpressure Endpoint

for Flammable Substances
For the worst-case scenario involving a release of flammable gases and volatile flammable
liquids, use the following methods to estimate the consequences of the worst-case scenario.
5.1 Flammable Substances Not in Mixtures

For the worst-case analysis of a regulated flammable substance that is not in a mixture with other
substances, you may estimate the consequence distance for a given quantity of a regulated flam-
mable substance using Reference Table 13. This table provides distances to 1 psi overpressure for
vapor cloud explosions of quantities from 500 to 2,000,000 pounds. These distances were esti-
mated by a TNT-equivalent model, Equation C-1 in Appendix C, Section C.1, using the worst-case
assumptions described above and data provided in Exhibit C-1, Appendix C. If you prefer, you may
calculate your worst-case consequence distance for flammable substances from the heat of com-
bustion of the flammable substance and Equation C-1 or C-2.
Example 16: Vapor Cloud Explosion (Propane)

You have a tank containing 50,000 pounds of propane. From Reference Table 13, the dis-
tance to 1 psi overpressure is 0.3 miles for 50,000 pounds of propane.
Alternatively, you can calculate the distance to 1 psi using Equation C-2 from Appendix C:
D = 0.0081 x [ 0.1 x 50,000 x (46,333/4,680) ]1/3
D = 0.3 miles
5.1.1 Substances Stored in a Gaseous State or Liquefied Under
Pressure
In these cases, it must be assumed that the total substance mass in the receptacle or the piping
is released as a gas, and this, over a period of 10 minutes. All the mass released in this way is
presumed exploded. The efficiency factor of the explosion will be 10% and the impact radius
will be obtained by using Reference Table 13.
5.1.2 Unconfined Emissions of a Pure Flammable Substance,
Liquefied by Refrigeration Only
Treat these cases like that of a substance stored in a gaseous state or liquefied under pressure
(see Section 5.1.1).
The entire volume spilled in this manner is presumed to evaporate in 10 minutes and partici-
pates in the explosion with an efficiency factor of 10%. Reference Table 13 will allow evaluat-
ing the impact radius of the explosion.
5.1.3 Unconfined Emissions of Pure Substances, Liquid at
Ambient Temperature and at Atmospheric Pressure
In these cases, it must be assumed that the total mass in the receptacle or the piping is instan-
taneously spilled to form a liquid pool of maximum dimension (i.e., 1-cm thickness). The surface
of the pool will be calculated using the Equation 3 method:
Equation 3: Amax = QS x DF
where:
Amax = Maximum surface of the liquid pool of 1-cm thickness (square feet)
QS = Theoretic storage capacity of the reservoir or pipe (pounds)
DF = Density factor (Exhibit C-3)
Thus, it will be assumed that the total quantity of substance released during the first 10 min-
utes of the evaporation will therefore be involved in the explosion, and this, with an efficiency
factor of 10%.
Annex 6
The quantity of the evaporated liquid substance, in wind speed conditions of 1.5 meters per
second, during the first 10 minutes, will be calculated using Equation 4:
Equation 4: QR = 1.4 x LFA x Amax
where:
LFA = Liquid factor at ambient temperature (25°C) (Exhibit C-3)
Amax = Maximum surface of the liquid pool of 1-cm thickness (square feet)
The total quantity of substance evaporated in this manner, during the first 10 minutes, will be
calculated using Equation 16:
Equation 16: Q10 min = QR x 10 minutes
Use this quantity at Reference Table 13 to determine the impact radius of the explosion of this
quantity of flammable substance.
5.1.4 Unconfined Emissions of Pure Substances, Liquid at
Ambient Temperature and at Atmospheric Pressure
If the spill is limited to inside a diked area, the surface of this area will be used as surface of the
liquid pool to calculate the release rate in the atmosphere by evaporation, in wind conditions of
1.5 meters per second:
Equation 8: QR = 1.4 x LFA x A
where:
LFA = Liquid factor at ambient temperature (25°C) (Exhibit C-3)
A = Surface of the diked liquid pool (square feet)
It will thus be assumed that the total quantity of substance released in the atmosphere during
the first 10 minutes of evaporation will be involved in the explosion, and this, with an efficien-
cy factor of 10%.
Make sure that the volume of the liquid does not exceed the volume of the diked area.
If this is the case, the excess volume must be estimated and the pool surface of 1-cm thickness
must be calculated; this surface must be added to the surface of the diked area to calculate the
release rate. The release rate will be calculated the same way as toxic liquids at Section 3.2.3.
5.1.5 Flammable Gases, Liquefied by Refrigeration Only
It must be assumed that the total quantity of liquid gas is spilled instantaneously and the liquid
pool, at its boiling point, evaporates according to the same conditions found in Section 3.1.3.
If the spill is limited to inside a diked area, the surface of this area will be used as surface of the
liquid pool to calculate the release rate in the atmosphere by evaporation, in wind conditions of
1.5 meters per second:
Equation 9: QR = 1.4 x LFB x A

Annex 6
where:
LFB = Liquid boiling factor (>25°C) (Exhibit C-2)
A = Surface of the diked liquid pool (square feet)
It will thus be assumed that the total quantity of substance released in the atmosphere during
the first 10 minutes of evaporation will be involved in the explosion, and this, with an efficien-
cy factor of 10%.
5.2 Flammable Mixtures

If you have more than 10,000 pounds of a mixture of flammable substances that meets the cri-
teria for listing under CAA section 112(r) (flash point below 22.8°C (73°F), boiling point below
37.8°C (100°F), National Fire Protection Association (NFPA) flammability hazard rating of 4), you
may need to carry out a worst-case consequence analysis for the mixture. (If the mixture itself
does not meet these criteria, it is not covered, and no analysis is required, even if the mixture
contains one or more regulated substances.) You should carry out the analysis using the total
quantity of all regulated flammable substance or substances in the mixture. Non-flammable
components should not be included. However, if additional (non-regulated) flammable sub-
stances are present in the mixture, you should include them in the quantity used in the analy-
sis.
For simplicity, you may carry out the worst-case analysis based on the predominant regulated
flammable component of the mixture or a major component of the mixture with the highest
heat of combustion if the whole vapor cloud consists of flammable substances (see Exhibit C-1,
Appendix C for data on heat of combustion). Estimate the consequence distance from
Reference Table 13 for the major component with the highest heat of combustion, assuming
that the quantity in the cloud is the total quantity of the mixture. If you have a mixture in which
the heats of combustion of the components do not differ significantly (e.g., a mixture of hydro-
carbons), this method is likely to give reasonable results.
Alternatively, you may estimate the heat of combustion of the mixture from the heats of com-
bustion of the components of the mixture using the method described in Appendix C, Section
C.2, and then use Equation C-1 or C-2 in Appendix C to determine the vapor cloud explosion
distance. This method may be appropriate if you have a mixture that includes components with
significantly different heats of combustion (e.g., a mixture of hydrogen and hydrocarbons) that
make up a significant portion of the mixture. Examples 17 and 18 illustrate the two methods of
analysis. In Example 17, the heat of combustion of the mixture is estimated, and the distance
to the endpoint is calculated from Equation C-2. In Example 18, the component of the mixture
with the highest heat of combustion is assumed to represent the entire mixture, and the dis-
tance to the endpoint is read from Reference Table 13. For the mixture of two hydrocarbons
used in the example, the methods give very similar results.

Annex 6
Excerpt from Appendix C

(Section C.1)
Equation C-1: D = 17 x (0.1 x Wf x HCf / HCTNT)1/3
where:
D = Distance to overpressure of 1 psi (meters)
Wf = Weight of flammable substance (kilograms or pounds/2.2)
HCf = Heat of combustion of flammable substance (kilojoules per kilogram)
(listed in Exhibit C-1)
HCTNT = Heat of explosion of trinitrotoluene (TNT) (4,680 kilojoules per kilogram)
The factor 17 is a constant for damages associated with 1.0 psi overpressures. The factor 0.1
represents an explosion efficiency of 10 percent. To convert distances from meters to miles, mul-
tiply by 0.00062.
Equation C-2: Dmi = 0.0081 x ( 0.1 x Wlb x HCf / HCTNT )1/3

where:
Dmi = Distance to overpressure of 1 psi (miles)
Wlb = Weight of flammable substance (pounds)
(Section C.2)
For a mixture of flammable substances, you may estimate the heat of combustion of the mix-
ture from the heats of combustion of the components of the mixture using the equation below
and then use the equation given in the previous section of this appendix to determine the vapor
cloud explosion distance. The heat of combustion of the mixture may be estimated as follows:
Equation C-3: HCm = Wx / Wm x HCx + Wy / Wm x HCy

where:
HCm = Heat of combustion of mixture (kilojoules per kilogram)
Wx = Weight of component “X” in mixture (kilograms or pounds/2.2)
Wm = Total weight of mixture (kilograms or pounds/2.2)
HCx = Heat of combustion of component “X” (kilojoules per kilogram)
Wy = Weight of component “Y” in mixture (kilograms or pounds/2.2)
HCy = Heat of combustion of component “Y” (kilojoules per kilogram)
Heats of combustion for regulated flammable substances are listed in Exhibit C-1 in the next
section (Section C.3) of this appendix.

Annex 6
Example 17: Estimating Heat of Combustion of Mixture for Vapor Cloud Explosion Analysis
You have a mixture of 8,000 pounds of ethylene (the reactant) and 2,000 pounds of isobu-
tane (a catalyst carrier). To carry out the worst-case analysis, estimate the heat of combustion
of the mixture from the heats of combustion of the components of the mixture. (Ethylene
heat of combustion = 47,145 kilojoules per kilogram; isobutane heat of combustion =
45,576.)
Using Equation C-3, Appendix C:
HCm = [ (8,000/2.2) x 47,145 ] + [ (2,000/2.2) x 45,576 ]
(10,000/2.2) (10,000/2.2)
HCm = (37,716) + (9,115)
HCm = 46,831 kilojoules per kilogram
Now use the calculated heat of combustion for the mixture in Equation C-2 to calculate the
distance to 1 psi overpressure for vapor cloud explosion.
D = 0.0081 x [ 0.1 x 10,000 x (46,831/4,680) ]1/3
D = 0.2 miles
Example 18: Vapor Cloud Explosion of Flammable Mixture (Ethylene and Isobutane)
You have 10,000 pounds of a mixture of ethylene (the reactant) and isobutane (a catalyst car-
rier). To carry out the worst-case analysis, assume the quantity in the cloud is the total quanti-
ty of the mixture. Use data for ethylene because it is the component with the highest heat of
combustion. (Ethylene heat of combustion = 47,145 kilojoules per kilogram; isobutane heat
of combustion = 45,576, from Exhibit C-1, Appendix C.)
From Reference Table 13, the distance to 1 psi overpressure is 0.2 miles for 10,000 pounds of
ethylene; this distance would also apply to the 10,000-pound mixture of ethylene and isobu-
tane.

290
EXHIBIT B-1 — DATA FOR TOXIC GASES
Annex 6
Ratio of Toxic Endpointa Liquid Factor Density Gas Vapor

Molecular
CAS No. Chemical Name Specific Boiling Factor Factor Pressure Reference Tableb
Weight mg/L ppm Basis (LFB) (DF) (Boiling)
Heats (GF) k @25oC (psia)
7664-41-7 Ammonia (anhydrous)c 17.03 1.31 0.14 200 ERPG-2 0.073 0.71 14 145 Buoyantd
7784-42-1 Arsine 77.95 1.28 0.0019 0.6 EHS-LOC (IDLH) 0.23 0.30 30 239 Dense
10294-34-5 Boron trichloride 117.17 1.15 0.010 2 EHS-LOC (Toxe) 0.22 0.36 36 22.7 Densee
7637-07-2 Boron trifluoride 67.81 1.20 0.028 1 EHS-LOC (IDLH) 0.25 0.31 28 f Dense
7782-50-5 Chlorine 70.91 1.32 0.0087 3 ERPG-2 0.19 0.31 29 113 Dense
10049-04-4 Chlorine dioxide 67.45 1.25 0.0028 1 EHS-LOC 0.15 0.30 28 24.3 Dense
equivalent (IDLH)g
506-77-4 Cyanogen chloride 61.47 1.22 0.030 12 EHS-LOC 0.14 0. 41 26 23.7 Dense
equivalent (Tox)h
19287-45-7 Diborane 27.67 1.17 0.0011 1 ERPG-2 0.13 1.13 17 f Buoyantd
75-21-8 Ethylene oxide 44.05 1.21 0.090 50 ERPG-2 0.12 0.55 22 25.4 Dense
7782-41-4 Fluorine 38.00 1.36 0.0039 2.5 EHS-LOC (IDLH) 0.35 0. 32 22 f Dense
50-00-0 Formaldehyde 30.03 1.31 0.012 10 ERPG-2 0.10 0.59 19 75.2 Densec
(anhydrous)
74-90-8 Hydrocyanic acid 27.03 1.30 0.011 10 ERPG-2 0.079 0.72 18 14.8 Buoyantd
7647-01-0 Hydrogen chloride 36.46 1.40 0.030 20 ERPG-2 0.15 0.41 21 684 Dense
(anhydrous)c
7664-39-3 Hydrogen fluoride 20.01 1.40 0.016 20 ERPG-2 0.066 0.51 16 17.7 Buoyanti
(anhydrous)c
7783-07-5 Hydrogen selenide 80.98 1.32 0.00066 0.2 EHS-LOC (IDLH) 0.21 0.25 31 151 Dense
7783-06-4 Hydrogen sulfide 34.08 1.32 0.042 30 ERPG-2 0.13 0.51 20 302 Dense
74-87-3 Methyl chloride 50.49 1.26 0.82 400 ERPG-2 0.14 0.48 24 83.2 Dense
74-93-1 Methyl mercaptan 48.11 1.20 0.049 25 ERPG-2 0.12 0.55 23 29.2 Dense
Risk Management Guide for Major Industrial Accidents

EXHIBIT B-1 — DATA FOR TOXIC GASES — END

Molecular
10102-43-9 Nitric oxide 30.01 1.38 0.031 25 EHS-LOC (TLVj) 0.21 0.38 19 f Dense
75-44-5 Phosgene 98.92 1.17 0.00081 0.2 ERPG-2 0.20 0.35 33 27.4 Dense
7803-51-2 Phosphine 34.00 1.29 0.0035 2.5 ERPG-2 0.15 0.66 20 567 Dense
7446-09-5 Sulfur dioxide 64.07 1.26 0.0078 3 ERPG-2 0.16 0.33 27 58.0 Dense
(anhydrous)
7783-60-0 Sulfur tetrafluoride 108.06 1.30 0.0092 2 EHS-LOC (Toxe) 0.25 0.25 36 293 Dense
(at -73°C)
Notes:

a = Toxic endpoints are specified in Appendix A to 40 CFR part 68 in units of mg/L.
To convert from units of mg/L to mg/m3, multiply by 1,000. To convert mg/L to ppm, use the following equation: Endpointppm = Endpointmg/L x 1,000 x 24.5
b = “Buoyant” in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; Molecular Weight
“Dense” refers to the tables for dense gases and vapors.
See Appendix D, Section D.4.4, for more information on the choice of reference tables.
c = See Exhibit B-3 of this appendix for data on water solutions.
d = Gases that are lighter than air may behave as dense gases upon release if liquefied under pressure or cold; consider the conditions of release when choosing the appropriate table.
e = LOC is based on the IDLH-equivalent level estimated from toxicity data.
f = Cannot be liquefied at 25°C.
g = Not an EHS; LOC-equivalent value was estimated from one-tenth of the IDLH.
h = Not an EHS; LOC-equivalent value was estimated from one-tenth of the IDLH-equivalent level estimated from toxicity data.
i = Hydrogen fluoride is lighter than air, but may behave as a dense gas upon release under some circumstances (e.g., release under pressure, high concentration in the released cloud)
because of hydrogen bonding; consider the conditions of release when choosing the appropriate table.
j = LOC based on Threshold Limit Value (TLV) - Time-weighted average (TWA) developed by the American Conference of Governmental Industrial Hygienists (ACGIH).
k = Use GF for gas leaks under choked (maximum) flow conditions.
Annex 6
291
292
EXHIBIT B-1A — DATA FOR TOXIC GASES
Annex 6

Molecular
74-83-9 Methyl bromide 94.94 1.24 0.194 50 ERPG-2 0.20 0.28 33 31.5 Dense
463-51-4 Ketene 42.04 1.21 0.003 1.5 TEEL 0.15 0.61 22 185.6 Dense
10102-44-0 Nitrogen tetroxide 46.01 1.29 0.028 1.5 TEEL 0.11 0.34 23 17.4 Dense
7616-94-6 Perchloryl fluoride 102.4 1.15 0.042 10 IDLH/10 0.25 0.29 33 172.6 Dense
630-08-0 Carbon monoxide 28.01 1.40 0.400 350 ERPG-2 0.30 1.65 19 7005.3 Dense
7803-52-3 Stibine N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Equations:
LFA = 0.284 x (molecular weight)2/3 x vapor pressure (mm Hg) / (82.05 x 298)
LFB = 0.284 x (molecular weight)2/3 x 760 / (82.05 x boiling point (K) )
DF = 1 / (density (lb / ft3 ) x 0.033)
GF = 132.2 x 6,895 x 6.4516 E-4 x 0.8 (γ x (2 / (γ+1)γ+ 1/ γ -1 ) )1/2 x molecular weight / 8,314)1/2
Equation D-11: γ+1

2 γ-1 MW
GF = 132.2 x 6,895 x 6.4516 x 10-4 x 0.8 γ x
( γ+1 ) 8,314
Note:
N/A = not available
April 8, 2000

EXHIBIT B-2 — DATA FOR TOXIC LIQUIDS
Molecular Vapor Toxic Endpointa Liquid Factors Density Liquid Leak Reference Tableb
CAS No. Chemical Name Pressure Factor Factor i
Weight at 25°C
Ambient (LFA) Boiling (LFB) (DF) (LLF) Worst Case Alternative Case
(mm Hg) mg/L ppm Basis
107-02-8 Acrolein 56.06 274 0.0011 0.5 ERPG-2 0.047 0.12 0.58 40 Dense Dense
107-13-1 Acrylonitrile 53.06 108 0.076 35 ERPG-2 0.018 0.11 0.61 39 Dense Dense
814-68-6 Acrylyl chloride 90.51 110 0.00090 0.2 EHS-LOC (Toxc) 0.026 0.15 0.44 54 Dense Dense
107-18-6 Allyl alcohol 58.08 26.1 0.036 15 EHS-LOC (IDLH) 0.0046 0.11 0.58 41 Dense Buoyantd
107-11-9 Allylamine 57.10 242 0.0032 1 EHS-LOC (Toxc) 0.042 0.12 0.64 36 Dense Dense
7784-34-1 Arsenous trichloride 181.28 10 0.01 1 EHS-LOC (Toxc) 0.0037 0.21 0.23 100 Dense Buoyantd
353-42-4 Boron trifluoride compound 113.89 11 0.023 5 EHS-LOC (Toxc) 0.0030 0.16 0.49 48 Dense Buoyantd
with methyl ether (1:1)
7726-95-6 Bromine 159.81 212 0.0065 1 ERPG-2 0.073 0.23 0.16 150 Dense Dense

75-15-0 Carbon disulfide 76.14 359 0.16 50 ERPG-2 0.075 0.15 0.39 60 Dense Dense
67-66-3 Chloroform 119.38 196 0.49 100 EHS-LOC (IDLH) 0.055 0.19 0.33 71 Dense Dense
542-88-1 Chloromethyl ether 114.96 29.4 0.00025 0.05 EHS-LOC (Toxc) 0.0080 0.17 0.37 63 Dense Dense
107-30-2 Chloromethyl 80.51 199 0.0018 0.6 EHS-LOC (Toxc) 0.043 0.15 0.46 51 Dense Dense
methyl ether
4170-30-3 Crotonaldehyde 70.09 33.1 0.029 10 ERPG-2 0.0066 0.12 0.58 41 Dense Buoyantd
123-73-9 Crotonaldehyde, (E)- 70.09 33.1 0.029 10 ERPG-2 0.0066 0.12 0.58 41 Dense Buoyantd
108-91-8 Cyclohexylamine 99.18 10.1 0.16 39 EHS-LOC (Toxc) 0.0025 0.14 0.56 41 Dense Buoyantd
75-78-5 Dimethyldichlorosilane 129.06 141 0.026 5 ERPG-2 0.042 0.20 0.46 51 Dense Dense
57-14-7 1,1-Dimethylhydrazine 60.10 157 0.012 5 EHS-LOC (IDLH) 0.028 0.12 0.62 38 Dense Dense
106-89-8 Epichlorohydrin 92.53 17.0 0.076 20 ERPG-2 0.0040 0.14 0.42 57 Dense Buoyantd
107-15-3 Ethylenediamine 60.10 12.2 0.49 200 EHS-LOC (IDLH) 0.0022 0.13 0.54 43 Dense Buoyantd
151-56-4 Ethyleneimine 43.07 211 0.018 10 EHS-LOC (IDLH) 0.030 0.10 0.58 40 Dense Dense
Annex 6
293
294
EXHIBIT B-2 — DATA FOR TOXIC LIQUIDS — CONTINUED
Annexe 6
Weight at 25°C (DF) (LLF)
(mm Hg) mg/L ppm Basis Ambient (LFA) Boiling (LFB) Worst Case Alternative Case
110-00-9 Furan 68.08 600 0.0012 0.4 EHS-LOC (Toxc) 0.12 0.14 0.52 45 Dense Dense
302-01-2 Hydrazine 32.05 14.4 0.011 8 EHS-LOC (IDLH) 0.0017 0.069 0.48 48 Buoyantd Buoyantd
13463-40-6 Iron, pentacarbonyl- 195.90 40 0.00044 0.05 EHS-LOC (Toxc) 0.016 0.24 0.33 70 Dense Dense
78-82-0 Isobutyronitrile 69.11 32.7 0.14 50 ERPG-2 0.0064 0.12 0.63 37 Dense Buoyantd
108-23-6 Isopropyl 122.55 28 0.10 20 EHS-LOC (Toxc) 0.0080 0.17 0.45 52 Dense Dense
chloroformate
126-98-7 Methacrylonitrile 67.09 71.2 0.0027 1 EHS-LOC (TLVe) 0.014 0.12 0.61 38 Dense Dense
79-22-1 Methyl chloroformate 94.50 108 0.0019 0.5 EHS-LOC (Toxc) 0.026 0.16 0.40 58 Dense Dense
60-34-4 Methyl hydrazine 46.07 49.6 0.0094 5 EHS-LOC (IDLH) 0.0074 0.094 0.56 42 Dense Buoyantd
624-83-9 Methyl isocyanate 57.05 457 0.0012 0.5 ERPG-2 0.079 0.13 0.52 45 Dense Dense
556-64-9 Methyl thiocyanate 73.12 10 0.085 29 EHS-LOC (Toxc) 0.0020 0.11 0.45 51 Dense Buoyantd
75-79-6 Methyltrichlorosilane 149.48 173 0.018 3 ERPG-2 0.057 0.22 0.38 61 Dense Dense
13463-39-3 Nickel carbonyl 170.73 400 0.00067 0.1 EHS-LOC (Toxc) 0.14 0.26 0.37 63 Dense Dense
7697-37-2 Nitric acid (100%)f 63.01 63.0 0.026 10 EHS-LOC (Toxc) 0.012 0.12 0.32 73 Dense Dense
79-21-0 Peracetic acid 76.05 13.9 0.0045 1.5 EHS-LOC (Toxc) 0.0029 0.12 0.40 58 Dense Buoyantd
594-42-3 Perchloro- 185.87 6 0.0076 1 EHS-LOC (IDLH) 0.0023 0.20 0.29 81 Dense Buoyantd
methylmercaptan
10025-87-3 Phosphorus oxychloride 153.33 35.8 0.0030 0.5 EHS-LOC (Toxc) 0.012 0.20 0.29 80 Dense Dense
7719-12-2 Phosphorus trichloride 137.33 120 0.028 5 EHS-LOC (IDLH) 0.037 0.20 0.31 75 Dense Dense
110-89-4 Piperidine 85.15 32.1 0.022 6 EHS-LOC (Toxc) 0.0072 0.13 0.57 41 Dense Buoyantd
107-12-0 Propionitrile 55.08 47.3 0.0037 1.6 EHS-LOC (Toxc) 0.0080 0.10 0.63 37 Dense Buoyantd
109-61-5 Propyl chloroformate 122.56 20.0 0.010 2 EHS-LOC (Toxc) 0.0058 0.17 0.45 52 Dense Buoyantd

EXHIBIT B-2 — DATA FOR TOXIC LIQUIDS — END
75-55-8 Propyleneimine 57.10 187 0.12 50 EHS-LOC (IDLH) 0.032 0.12 0.61 39 Dense Dense
75-56-9 Propylene oxide 58.08 533 0.59 250 ERPG-2 0.093 0.13 0.59 40 Dense Dense
7446-11-9 Sulfur trioxide 80.06 263 0.010 3 ERPG-2 0.057 0.15 0.26 91 Dense Dense
75-74-1 Tetramethyllead 267.33 22.5 0.0040 0.4 EHS-LOC (IDLH) 0.011 0.29 0.24 96 Dense Dense
509-14-8 Tetranitromethane 196.04 11.4 0.0040 0.5 EHS-LOC (IDLH) 0.0045 0.22 0.30 78 Dense Buoyantd
7550-45-0 Titanium tetrachloride 189.69 12.4 0.020 2.6 ERPG-2 0.0048 0.21 0.28 82 Dense Buoyantd
584-84-9 Toluene 2,4-diisocyanate 174.16 0.017 0.0070 1 EHS-LOC (IDLH) 0.000006 0.16 0.40 59 Buoyantd Buoyantd
91-08-7 Toluene 2,6-diisocyanate 174.16 0.05 0.0070 1 EHS-LOC (IDLHg) 0.000018 0.16 0.40 59 Buoyantd Buoyantd
26471-62-5 Toluene diisocyanate 174.16 0.017 0.0070 1 EHS-LOC equivalent 0.000006 0.16 0.40 59 Buoyantd Buoyantd
(unspecified isomer) (IDLHh)

75-77-4 Trimethylchlorosilane 108.64 231 0.050 11 EHS-LOC (Toxc) 0.061 0.18 0.57 41 Dense Dense
108-05-4 Vinyl acetate monomer 86.09 113 0.26 75 ERPG-2 0.026 0.15 0.53 45 Dense Dense
Notes:
a = Toxic endpoints are specified in the Appendix A to 40 CFR part 68 in units of mg/L.
To convert from units of mg/L to mg/m3, multiply by 1,000.
To convert mg/L to ppm, use the following equation: Endpointppm = Endpointmg/L x 1,000 x 24.5
Molecular Weight
b = “Buoyant” in the Reference Table column refers to the tables for neutrally buoyant gases and vapors;
c = LOC is based on IDLH-equivalent level estimated from toxicity data.
d = Use dense gas table if substance is at an elevated temperature.
e = LOC based on Threshold Limit Value (TLV). Time-weighted average (TWA) developed by the American Conference of Governmental Industrial Hygienists (ACGIH).
f = See Exhibit B-3 of this appendix for data on water solutions.
g = LOC for this isomer is based on IDLH for toluene 2,4-diisocyanate.
h = Not an EHS; LOC-equivalent value is based on IDLH for toluene 2,4-diisocyanate.
i = Use the LLF only for leaks from tanks at atmospheric pressure.
Annex 6
April 8, 2000
295
296
EXHIBIT B-2A — DATA FOR TOXIC LIQUIDS
Annex 6
Molecular Vapor Toxic Endpoint Liquid Factors Density Liquid Leak Reference Table
CAS No. Chemical Name Pressure Factor Factor
7790-94-5 Chlorosulfonic acid 116.5 3.19 0.047 10 ERPG-2 8.80E-04 0.15 0.28 84 Dense Dense
506-68-3 Cyanogen bromide 105.9 121.40 0.0061 1.4 CMMI (1998/10/18) 0.032 0.18 0.24 97 Dense Dense
10035-10-6 Hydrobromic acid 80.91 18447 3 0.0099 CMMI (1998/10/18) 8.00E-05 N/A 0.32 73 Dense Dense
107-07-3 Ethylene chlorohydrin 80.51 7.14 2.30E-04 0.07 IDLH/10 0.0015 0.12 0.41 58 Dense Dense
76-06-2 Chloropicrin 164.39 27.25 0.0013 0.20 ERPG-2 0.009 0.20 0.29 80 Dense Dense
107-05-1 Allyl chloride 76.53 367.01 0.12 40 ERPG-2 0.077 0.15 0.52 45 Dense Dense
7719-09-7 Thionyl chloride 119 118.78 0.24 50 CMMI (1998/10/18) 0.033 0.18 0.30 79 Dense Dense
lowest conc. 1 h
74-88-4 Methyl iodide 141.9 403.49 0.29 50 ERPG-2 0.13 0.23 0.21 110 Dense Dense
7439-97-6 Mercury 200.6 0.00194 0.0001 0.012 TEEL 7.70E-07 0.14 0.04 652 Dense Dense
30674-80-7 2-Isocyanatoethyl N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
methacrylate
78-94-4 Methyl vinyl ketone 70.09 27.25 0.2 0.0013 M.L. Lefebvre 0.014 0.13 0.56 42 Dense Dense
78-85-3 Methacrylaldehyde 70.09 150.14 N/A N/A N/A 0.03 0.13 0.58 41 Dense Dense
108-95-2 Phenol 94.11 0.42 0.19 50 ERPG-2 1.00E-04 0.12 0.45 52 Dense Dense
78-00-2 Tetraethyl lead 323.4 0.39 0.004 0.3 IDLH/10 2, 2-4 0.26 0.29 80 Dense Dense
20816-12-0 Osmium tetroxide 254.1 6.61 1.30E-05 1.25E-03 TEEL 0.003 0.26 0.10 237 Dense Dense
76-06-2 Trichloronitromethane N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
(in mixture)
Equations:
LFB = 0.284 x (molecular weight)2/3 x 760 / (82.05 x boiling point (K))
DF = 1 / (density (lb / ft3 ) x 0.033)
LLF = 132.2 x 6.4516 E-4 x 0.1594 x 0.8 x (2 x 9.8)1/2 x liquid density (kg/m3 )
Equation D-17: LLF = 132.2 x 6.4516 x 10-4 x 0.1594 x 0.8 x 2 x 9.8 x ρl

Notes:
Hydrobromic acid taken as 50% solution
N/A = not available
April 8, 2000
EXHIBIT B-3 — DATA FOR WATER SOLUTIONS OF TOXIC SUBSTANCES AND FOR OLEUM
FOR WIND SPEEDS OF 1.5 AND 3.0 METERS PER SECOND (M/S)
Toxic Endpointa Initial 10- min. Average Liquid Factor at Density Liquid Reference Tableb
Regulated Substance Molecular Concentration Vapor Pressure (mm Hg) 25°C (LFA) Factor Leak Factor
CAS No.
in Solution Weight mg/L ppm Basis (Wt %) (DF) (LLF) Worst Alternative
1.5 m/s 3.0 m/s 1.5 m/s 3.0 m/s
7664-41-7 Ammonia 17.03 0.14 200 ERPG-2 30 332 248 0.026 0.019 0.55 43 Buoyant Buoyant
24 241 184 0.019 0.014 0.54 44 Buoyant Buoyant
20 190 148 0.015 0.011 0.53 44 Buoyant Buoyant
50-00-0 Formaldehyde 30.027 0.012 10 ERPG-2 37 1.5 1.4 0.0002 0.0002 0.44 53 Buoyant Buoyant
7647-01-0 Hydrochloric acid 36.46 0.030 20 ERPG-2 38 78 55 0.010 0.0070 0.41 57 Dense Buoyantd
37 67 48 0.0085 0.0062 0.42 57 Dense Buoyantd
36c 56 42 0.0072 0.0053 0.42 57 Dense Buoyantd
34c 38 29 0.0048 0.0037 0.42 56 Dense Buoyantd

30c 13 12 0.0016 0.0015 0.42 55 Buoyantd Buoyantd
7664-39-3 Hydrofluoric acid 20.01 0.016 20 ERPG-2 70 124 107 0.011 0.010 0.39 61 Buoyant Buoyant
50 16 15 0.0014 0.0013 0.41 58 Buoyant Buoyant
7697-37-2 Nitric acid 63.01 0.026 10 EHS- 90 25 22 0.0046 0.0040 0.33 71 Dense Buoyantd
LOC 85 17 16 0.0032 0.0029 0.33 70 Dense Buoyantd
(IDLH) 80 10.2 10 0.0019 0.0018 0.33 70 Dense Buoyantd
8014-95-7 Oleum - based 80.06 0.010 3 ERPG-2 30 (SO3) 3.5 (SO3) 3.4 (SO3) 0.0008 0.0007 0.25 93 Buoyantd Buoyantd
on SO3 (SO3)
Notes:
a = Toxic endpoints are specified in the Appendix A to 40 CFR part 68 in units of mg/L. See Notes to Exhibit B-1 or B-2 for converting to other units.
b = “Buoyant” in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; “Dense” refers to the tables for dense gases and vapors.
c = Hydrochloric acid in concentrations below 37 percent is not regulated.
d = Use dense gas table if substance is at an elevated temperature.
April 8, 2000
Annex 6
297
Annex 6
EXHIBIT B-4 — TEMPERATURE CORRECTION FACTORS

FOR LIQUIDS EVAPORATING FROM POOLS AT TEMPERATURES BETWEEN 25 C O
AND 50 C (77 F
O O
AND 122 F)O
Boiling Temperature Correction Factor (TCF)

CAS No. Chemical Name
Point (°C) 30 C (86 F)
o o
35 C (95oF)
o
40oC (104oF) 45oC (113oF) 50oC (122oF)
107-02-8 Acrolein 52.69 1.2 1.4 1.7 2.0 2.3
107-13-1 Acrylonitrile 77.35 1.2 1.5 1.8 2.1 2.5
814-68-6 Acrylyl chloride 75.00 ND ND ND ND ND
107-18-6 Allyl alcohol 97.08 1.3 1.7 2.2 2.9 3.6
107-11-9 Allylamine 53.30 1.2 1.5 1.8 2.1 2.5
7784-34-1 Arsenous trichloride 130.06 ND ND ND ND ND
353-42-4 Boron trifluoride compound 126.85 ND ND ND ND ND
with methyl ether (1:1)
7726-95-6 Bromine 58.75 1.2 1.5 1.7 2.1 2.5
75-15-0 Carbon disulfide 46.22 1.2 1.4 1.6 1.9 LFB
67-66-3 Chloroform 61.18 1.2 1.5 1.8 2.1 2.5
542-88-1 Chloromethyl ether 104.85 1.3 1.6 2.0 2.5 3.1
107-30-2 Chloromethyl 59.50 1.2 1.5 1.8 2.1 2.5
methyl ether
4170-30-3 Crotonaldehyde 104.10 1.3 1.6 2.0 2.5 3.1
123-73-9 Crotonaldehyde, (E) 102.22 1.3 1.6 2.0 2.5 3.1
108-91-8 Cyclohexylamine 134.50 1.3 1.7 2.1 2.7 3.4
75-78-5 Dimethyldichlorosilane 70.20 1.2 1.5 1.8 2.1 2.5
57-14-7 1,1-Dimethylhydrazine 63.90 ND ND ND ND ND
106-89-8 Epichlorohydrin 118.50 1.3 1.7 2.1 2.7 3.4
107-15-3 Ethylenediamine 36.26 1.3 1.8 LFB LFB LFB
151-56-4 Ethyleneimine 55.85 1.2 1.5 1.8 2.2 2.7
110-00-9 Furan 31.35 1.2 LFB LFB LFB LFB
302-01-2 Hydrazine 113.50 1.3 1.7 2.2 2.9 3.6
13463-40-6 Iron, pentacarbonyl 102.65 ND ND ND ND ND
78-82-0 Isobutyronitrile 103.61 1.3 1.6 2.0 2.5 3.1
108-23-6 Isopropyl chloroformate 104.60 ND ND ND ND ND
126-98-7 Methacrylonitrile 90.30 1.2 1.5 1.8 2.2 2.6

Annex 6
EXHIBIT B-4 — TEMPERATURE CORRECTION FACTORS — END

FOR LIQUIDS EVAPORATING FROM POOLS AT TEMPERATURES BETWEEN 25 C O
AND 50 C (77 F AND 122 F)
O O O

Point (°C) 30oC (86oF) 35oC (95oF) 40oC (104oF) 45oC (113oF) 50oC (122oF)
79-22-1 Methyl chloroformate 70.85 1.3 1.6 1.9 2.4 2.9
60-34-4 Methyl hydrazine 87.50 ND ND ND ND ND
624-83-9 Methyl isocyanate 38.85 1.2 1.4 LFB LFB LFB
556-64-9 Methyl thiocyanate 130.00 ND ND ND ND ND
75-79-6 Methyltrichlorosilane 66.40 1.2 1.4 1.7 2.0 2.4
13463-39-3 Nickel carbonyl 42.85 ND ND ND ND ND
7697-37-2 Nitric acid 83.00 1.3 1.6 2.0 2.5 3.1
79-21-0 Peracetic acid 109.85 1.3 1.8 2.3 3.0 3.8
594-42-3 Perchloromethyl- 147.00 ND ND ND ND ND
mercaptan
10025-87-3 Phosphorus oxychloride 105.50 1.3 1.6 1.9 2.4 2.9
7719-12-2 Phosphorus trichloride 76.10 1.2 1.5 1.8 2.1 2.5
110-89-4 Piperidine 106.40 1.3 1.6 2.0 2.4 3.0
107-12-0 Propionitrile 97.35 1.3 1.6 1.9 2.3 2.8
109-61-5 Propyl chloroformate 112.40 ND ND ND ND ND
75-55-8 Propyleneimine 60.85 1.2 1.5 1.8 2.1 2.5
75-56-9 Propylene oxide 33.90 1.2 LFB LFB LFB LFB
7446-11-9 Sulfur trioxide 44.75 1.3 1.7 LFB LFB LFB
75-74-1 Tetramethyllead 110.00 ND ND ND ND ND
509-14-8 Tetranitromethane 125.70 1.3 1.7 2.2 2.8 3.5
7550-45-0 Titanium tetrachloride 135.85 1.3 1.6 2.0 2.6 3.2
584-84-9 Toluene 2,4-diisocyanate 251.00 1.6 2.4 3.6 5.3 7.7
91-08-7 Toluene 2,6-diisocyanate 244.85 ND ND ND ND ND
26471-62-5 Toluene diisocyanate 250.00 1.6 2.4 3.6 5.3 7.7
(unspecified isomer)
75-77-4 Trimethylchlorosilane 57.60 1.2 1.4 1.7 2.0 2.3
108-05-4 Vinyl acetate monomer 72.50 1.2 1.5 1.9 2.3 2.7
Notes:
ND = No data available.
LFB = Chemical above boiling point at this temperature; use LFB for analysis.
April 8, 2000

Annex 6
EXHIBIT B-4A — TEMPERATURE CORRECTION FACTORS

FOR LIQUIDS EVAPORATING FROM POOLS
AT TEMPERATURES BETWEEN 25°C AND 50°C (77°F AND 122°F)

Point (°C) 30°C (86 F)
o
35°C (95oF) 40°C (104oF) 45°C (113oF) 50°C (122oF)
71-43-2 Benzene 80.2 1.2 1.5 1.8 2.2 2.6
86290-81-5 Gasoline 66.3 1.2 1.4 1.6 1.9 2.1
110-82-7 Cyclohexane 80.9 1.2 1.5 1.8 2.2 2.6
107-06-2 Ethylene dichloride 83.6 1.2 1.5 1.9 2.3 2.7
100-41-4 Ethylbenzene 136.4 1.3 1.7 2.14 2.7 3.4
8006-14-2 Natural gas liquefied -161.5 N/A N/A N/A N/A N/A
8030-30-6 Naphtha 66.3 1.2 1.4 1.6 1.9 2.1
75-18-3 Dimethyl sulfide 37.5 1.2 1.4 1.6 1.9 2.2
75-64-9 t-Butylamine 44.5 1.2 1.4 1.7 2.0 2.3
108-88-3 Toluene 110.8 1.3 1.6 2.0 2.4 3.0
1330-20-7 Xylenes 139.3 1.3 1.7 2.2 2.7 3.4
7790-94-5 Chlorosulfonic acid 154 1.4 1.8 2.4 3.1 4.1
506-68-3 Cyanogen bromide 61.3 1.3 1.8 2.4 3.0 3.7
107-07-3 2-Chloroethanol 129 1.3 1.8 2.3 3.0 3.8
76-06-2 Chloropicrin 112.3 1.2 1.5 1.9 2.4 2.9
107-05-1 Allyl chloride 45.1 1.2 1.4 1.6 1.9 2.2
7719-09-7 Thionyl chloride 75.8 1.2 1.5 1.8 2.1 2.5
74-88-4 Methyl iodide 42.6 1.2 1.4 1.6 1.9 2.2
7439-97-6 Mercury 356.7 1.5 2.2 3.1 4.4 6.3
78-85-3 Methacylaldehyde 68.1 1.2 1.5 1.8 2.1 2.5
108-95-2 Phenol 182 1.5 2.1 3.0 4.1 5.7
78-00-2 Tetraethyl lead 200.1 1.4 2.0 2.8 3.8 5.1
Equation:
TCF = vapor pressureT x 298 / vapor pressure298 x T
Equation D-5: TCFT = VPT x 298

VP298 x T
Note:
N/A = not available
April 8, 2000

Annex 6
EXHIBIT C-1 — HEATS OF COMBUSTION

FOR FLAMMABLE SUBSTANCES
Physical State Heat of Combustion

at 25oC (kjoule/kg)
75-07-0 Acetaldehyde Gas 25,072
74-86-2 Acetylene [Ethyne] Gas 48,222
598-73-2 Bromotrifluoroethylene [Ethene, bromotrifluoro-] Gas 1,967
106-99-0 1,3-Butadiene Gas 44,548
106-97-8 Butane Gas 45,719
25167-67-3 Butene Gas 45,200*
590-18-1 2-Butene-cis Gas 45,171
624-64-6 2-Butene-trans [2-Butene, (E)] Gas 45,069
106-98-9 1-Butene Gas 45,292
107-01-7 2-Butene Gas 45,100*
463-58-1 Carbon oxysulfide [Carbon oxide sulfide (COS)] Gas 9,126
7791-21-1 Chlorine monoxide [Chlorine oxide] Gas 1,011*
590-21-6 1-Chloropropylene [1-Propene, 1-chloro-] Liquid 23,000*
557-98-2 2-Chloropropylene [1-Propene, 2-chloro-] Gas 22,999
460-19-5 Cyanogen [Ethanedinitrile] Gas 21,064
75-19-4 Cyclopropane Gas 46,560
4109-96-0 Dichlorosilane [Silane, dichloro-] Gas 8,225
75-37-6 Difluoroethane [Ethane, 1,1-difluoro-] Gas 11,484
124-40-3 Dimethylamine [Methanamine, N-methyl-] Gas 35,813
463-82-1 2,2-Dimethylpropane [Propane, 2,2-dimethyl-] Gas 45,051
74-84-0 Ethane Gas 47,509
107-00-6 Ethyl acetylene [1-Butyne] Gas 45,565
75-04-7 Ethylamine [Ethanamine] Gas 35,210
75-00-3 Ethyl chloride [Ethane, chloro-] Gas 19,917
74-85-1 Ethylene [Ethene] Gas 47,145
60-29-7 Ethyl ether [Ethane, 1,1’-oxybis-] Liquid 33,775
75-08-1 Ethyl mercaptan [Ethanethiol] Liquid 27,948
109-95-5 Ethyl nitrite [Nitrous acid, ethyl ester] Gas 18,000
1333-74-0 Hydrogen Gas 119,950
75-28-5 Isobutane [Propane, 2-methyl] Gas 45,576
78-78-4 Isopentane [Butane, 2-methyl-] Liquid 44,911
78-79-5 Isoprene [1,3-Butadiene, 2-methyl-] Liquid 43,809

Annex 6
EXHIBIT C-1 — HEATS OF COMBUSTION

FOR FLAMMABLE SUBSTANCES — END
Physical State Heat of Combustion

at 25oC (kjoule/kg)
75-31-0 Isopropylamine [2-Propanamine] Liquid 36,484
75-29-6 Isopropyl chloride [Propane, 2-chloro-] Liquid 23,720
74-82-8 Methane Gas 50,029
74-89-5 Methylamine [Methanamine] Gas 31,396
563-45-1 3-Methyl-1-butene Gas 44,559
563-46-2 2-Methyl-1-butene Liquid 44,414
115-10-6 Methyl ether [Methane, oxybis-] Gas 28,835
107-31-3 Methyl formate [Formic acid, methyl ester] Liquid 15,335
115-11-7 2-Methylpropene [1-Propene, 2-methyl-] Gas 44,985
504-60-9 1,3-Pentadiene Liquid 43,834
109-66-0 Pentane Liquid 44,697
109-67-1 1-Pentene Liquid 44,625
646-04-8 2-Pentene, (E)- Liquid 44,458
627-20-3 2-Pentene, (Z)- Liquid 44,520
463-49-0 Propadiene [1,2-Propadiene] Gas 46,332
74-98-6 Propane Gas 46,333
115-07-1 Propylene [1-Propene] Gas 45,762
74-99-7 Propyne [1-Propyne] Gas 46,165
7803-62-5 Silane Gas 44,307
116-14-3 Tetrafluoroethylene [Ethene, tetrafluoro-] Gas 1,284
75-76-3 Tetramethylsilane [Silane, tetramethyl-] Liquid 41,712
10025-78-2 Trichlorosilane [Silane, trichloro-] Liquid 3,754
79-38-9 Trifluorochloroethylene [Ethene, chlorotrifluoro-] Gas 1,837
75-50-3 Trimethylamine [Methanamine, N,N-dimethyl-] Gas 37,978
689-97-4 Vinyl acetylene [1-Buten-3-yne] Gas 45,357
75-01-4 Vinyl chloride [Ethene, chloro-] Gas 18,848
109-92-2 Vinyl ethyl ether [Ethene, ethoxy-] Liquid 32,909
75-02-5 Vinyl fluoride [Ethene, fluoro-] Gas 2,195
75-35-4 Vinylidene chloride [Ethene, 1,1-dichloro-] Liquid 10,354
75-38-7 Vinylidene fluoride [Ethene, 1,1-difluoro-] Gas 10,807
107-25-5 Vinyl methyl ether [Ethene, methoxy-] Gas 30,549
* Estimated heat of combustion
April 15, 1999

Annex 6
EXHIBIT C-1A — HEATS OF COMBUSTION

FOR FLAMMABLE SUBSTANCES
CAS No. Chemical Name Physical State at 25°C Heat of Combustion

(kjoule/kg)
71-43-2 Benzene Liquid 4.01E+04
86290-81-5 Gasoline Liquid 4.36E+04
110-82-7 Cyclohexane Liquid 4.35E+04
107-06-2 Ethylene dichloride Liquid 1.12E+04
100-41-4 Ethylbenzene Liquid 4.09E+04
8006-14-2 Natural gas liquefieda Liquid 3.14E+05
8030-30-6 Naphtha Liquid 4.36E+04
75-18-3 Dimethyl sulfide Liquid 2.80E+04
75-64-9 t-Butylamine Liquid 3.76E+04
108-88-3 Toluene Liquid 4.05E+04
1330-20-7 Xylenes Liquid 4.08E+04
Note:
a. Same data as methane
April 8, 2000

304
EXHIBIT C-2 — DATA FOR FLAMMABLE GASES
Annex 6
Molecular Ratio of Flammability Limits (Vol%) LFL Gas Factor Liquid Factor Density Reference Pool Fire Flash Fraction
CAS No. Chemical Name Specific Boiling Factor Tablea Factor Factor
Weight Heats Lower (LFL) Upper (UFL) (mg/L) (GF)g (LFB) (Boiling) (DF) (PFF) (FFF)f
75-07-0 Acetaldehyde 44.05 1.18 4.0 60.0 72 22 0.11 0.62 Dense 2.7 0.018
74-86-2 Acetylene 26.04 1.23 2.5 80.0 27 17 0.12 0.78 Buoyantb 4.8 0.23f
598-73-2 Bromotrifluoroethylene 160.92 1.11 c 37.0 c 41c 0.25c 0.29c Dense 0.42c 0.15c
106-99-0 1,3-Butadiene 54.09 1.12 2.0 11.5 44 24 0.14 0.75 Dense 5.5 0.15
106-97-8 Butane 58.12 1.09 1.5 9.0 36 25 0.14 0.81 Dense 5.9 0.15
25167-67-3 Butene 56.11 1.10 1.7 9. 5 39 24 0.14 0.77 Dense 5.6 0.14
590-18-1 2-Butene-cis 56.11 1.12 1.6 9.7 37 24 0.14 0.76 Dense 5.6 0.11
624-64-6 2-Butene-trans 56.11 1.11 1.8 9.7 41 24 0.14 0.77 Dense 5.6 0.12
106-98-9 1-Butene 56.11 1.11 1.6 9.3 37 24 0.14 0.78 Dense 5.7 0.17
107-01-7 2-Butene 56.11 1.10 1.7 9.7 39 24 0.14 0.77 Dense 5.6 0.12
463-58-1 Carbon oxysulfide 60.08 1.25 12.0 29.0 290 26 0.18 0.41 Dense 1.3 0.29
7791-21-1 Chlorine monoxide 86.91 1.21 23.5 NA 830 31 0.19 NA Dense 0.15 NA
557-98-2 2-Chloropropylene 76.53 1.12 4.5 16.0 140 29 0.16 0.54 Dense 3.3 0.011
460-19-5 Cyanogen 52.04 1.17 6.0 32.0 130 24 0.15 0.51 Dense 2.5 0.40
75-19-4 Cyclopropane 42.08 1.18 2.4 10.4 41 22 0.13 0.72 Dense 5.4 0.23
4109-96-0 Dichlorosilane 101.01 1.16 4.0 96.0 160 33 0.20 0.40 Dense 1.3 0.084
75-37-6 Difluoroethane 66.05 1.14 3.7 18.0 100 27 0.17 0.48 Dense 1.6 0.23
124-40-3 Dimethylamine 45.08 1.14 2.8 14.4 52 22 0.12 0.73 Dense 3.7 0.090
463-82-1 2,2-Dimethylpropane 72.15 1.07 1.4 7.5 41 27 0.16 0.80 Dense 6.4 0.11
74-84-0 Ethane 30.07 1.19 2.9 13.0 36 18 0.14 0.89 Dense 5.4 0.75

EXHIBIT C-2 — DATA FOR FLAMMABLE GASES — CONTINUED
107-00-6 Ethyl acetylene 54.09 1.11 2.0 32.9 44 24 0.13 0.73 Dense 5.4 0.091
75-04-7 Ethylamine 45.08 1.13 3.5 14.0 64 22 0.12 0.71 Dense 3.6 0.040
75-00-3 Ethyl chloride 64.51 1.15 3.8 15.4 100 27 0.15 0.53 Dense 2.6 0.053
74-85-1 Ethylene 28.05 1.24 2.7 36.0 31 18 0.14 0.85 Buoyantb 5.4 0.63f
109-95-5 Ethyl nitrite 75.07 1.30 4.0 50.0 120 30 0.16 0.54 Dense 2.0 NA
1333-74-0 Hydrogen 2.02 1.41 4.0 75.0 3.3 5.0 e e d e NA
75-28-5 Isobutane 58.12 1.09 1.8 8.4 43 25 0.15 0.82 Dense 6.0 0.23
74-82-8 Methane 16.04 1.30 5.0 15.0 33 14 0.15 1.1 Buoyant 5.6 0.87f
74-89-5 Methylamine 31.06 1.19 4.9 20.7 62 19 0.10 0.70 Dense 2.7 0.12

563-45-1 3-Methyl-1-butene 70.13 1.08 1.5 9.1 43 26 0.15 0.77 Dense 6.0 0.030
115-10-6 Methyl ether 46.07 1.15 3.3 27.3 64 22 0.14 0.66 Dense 3.4 0.22
115-11-7 2-Methylpropene 56.11 1.10 1.8 8.8 41 24 0.14 0.77 Dense 5.7 0.18
463-49-0 Propadiene 40.07 1.16 2.1 2.1 34 21 0.13 0.73 Dense 5.2 0.20
74-98-6 Propane 44.10 1.13 2.0 9.5 36 22 0.14 0.83 Dense 5.7 0.38
115-07-1 Propylene 42.08 1.15 2.0 11.0 34 21 0.14 0.79 Dense 5.5 0.35
74-99-7 Propyne 40.07 1.16 1.7 39.9 28 21 0.12 0.72 Dense 4.9 0.18
7803-62-5 Silane 32.12 1.24 19 Dense 0.41
116-14-3 Tetrafluoroethylene 100.02 1.12 11.0 60.0 450 33 0.29 0.32 Dense 0.25 0.69
79-38-9 Trifluorochloroethylene 116.47 1.11 8.4 38.7 400 35 0.26 0.33 Dense 0.34 0.27
75-50-3 Trimethylamine 59.11 1.10 2.0 11.6 48 25 0.14 0.74 Dense 4.8 0.12
Annex 6
305
306
EXHIBIT C-2 — DATA FOR FLAMMABLE GASES — END
Annex 6
689-97-4 Vinyl acetylene 52.08 1.13 2.2 31.7 47 24 0.13 0.69 Dense 5.4 0.086
75-01-4 Vinyl chloride 62.50 1.18 3.6 33.0 92 26 0.16 0.50 Dense 2.4 0.14
75-02-5 Vinyl fluoride 46.04 1.20 2.6 21.7 49 23 0.17 0.57 Dense 0.28 0.37
75-38-7 Vinylidene fluoride 64.04 1.16 5.5 21.3 140 27 0.22 0.42 Dense 18 0.50
107-25-5 Vinyl methyl ether 58.08 1.12 2.6 39.0 62 25 0.17 0.57 Dense 3.7 0.093
Notes:
NA = Data not available
a = “Buoyant” in the Reference Table column refers to the tables for neutrally buoyant gases and vapors;
b = Gases that are lighter than air may behave as dense gases upon release if liquefied under pressure or cold; consider the conditions of release when choosing the appropriate
table.
c = Reported to be spontaneously combustible.
d = Much lighter than air; table of distances for neutrally buoyant gases not appropriate.
e = Pool formation unlikely.
f = Calculated at 298K (25°C) with the following exceptions: • Acetylene factor at 250K as reported in TNO,
Methods for the Calculation of the Physical Effects of the Escape of Dangerous Material (1980).
• Ethylene factor calculated at critical temperature, 282K.
• Methane factor calculated at critical temperature, 191K.
• Silane factor calculated at critical temperature, 270K.
g = Use GF for gas leaks under choked (maximum) flow conditions.
April 8, 2000

EXHIBIT C-3 — DATA FOR FLAMMABLE LIQUIDS
Molecular Flammability Limit (Vol%) LFL Liquid Factor Density Liquid Reference Pool Fire
CAS No. Chemical Name Factor Leak Factora Factor
Weight Lower (LFL) Upper (UFL) (mg/L) Tableb
Ambient (LFA) Boiling (LFB) (DF) (LLF) (PFF)
590-21-6 1-Chloropropylene 76.53 4.5 16.0 140 0.11 0.15 0.52 45 Dense 3.2
60-29-7 Ethyl ether 74.12 1.9 48.0 57 0.11 0.15 0.69 34 Dense 4.3
75-08-1 Ethyl mercaptan 62.14 2.8 18.0 71 0.10 0.13 0.58 40 Dense 3.3
78-78-4 Isopentane 72.15 1.4 7.6 41 0.14 0.15 0.79 30 Dense 6.1
78-79-5 Isoprene 68.12 2.0 9.0 56 0.11 0.14 0.72 32 Dense 5.5
75-31-0 Isopropylamine 59.11 2.0 10.4 48 0.10 0.13 0.71 33 Dense 4.1
75-29-6 Isopropyl chloride 78.54 2.8 10.7 90 0.11 0.16 0.57 41 Dense 3.1
563-46-2 2-Methyl-1-butene 70.13 1.4 9.6 40 0.12 0.15 0.75 31 Dense 5.8
107-31-3 Methyl formate 60.05 5.9 20.0 140 0.10 0.13 0.50 46 Dense 1.8

504-60-9 1,3-Pentadiene 68.12 1.6 13.1 44 0.077 0.14 0.72 33 Dense 5.3
109-66-0 Pentane 72.15 1.3 8.0 38 0.10 0.15 0.78 30 Dense 5.8
109-67-1 1-Pentene 70.13 1.5 8.7 43 0.13 0.15 0.77 31 Dense 5.8
646-04-8 2-Pentene, (E) 70.13 1.4 10.6 40 0.10 0.15 0.76 31 Dense 5.6
627-20-3 2-Pentene, (Z) 70.13 1.4 10.6 40 0.10 0.15 0.75 31 Dense 5.6
75-76-3 Tetramethylsilane 88.23 1.5 NA 54 0.17 0.17 0.59 40 Dense 6.3
10025-78-2 Trichlorosilane 135.45 1.2 90.5 66 0.18 0.23 0.37 64 Dense 0.68
109-92-2 Vinyl ethyl ether 72.11 1.7 28.0 50 0.10 0.15 0.65 36 Dense 4.2
75-35-4 Vinylidene chloride 96.94 7.3 NA 290 0.15 0.18 0.44 54 Dense 1.6
Notes:
NA = Data not available.
a = Use the LLF only for leaks from tanks at atmospheric pressure.
b = “Dense” in the Reference Table column refers to the tables for dense gases and vapors.
April 15, 1999

Annex 6
307
308
EXHIBIT C-3A — DATA FOR FLAMMABLE LIQUIDS
Annex 6
Molecular Flammability Limit (Vol %) Liquid Factors Density Pool Fire

CAS No. Chemical Name LFL Factor Liquid Leak Reference Factor
Weight Lower (LFL) Upper (UFL) (mg/L) Ambient (LFA) Boiling (LFB) (DF) Factor (LLF) Table (PFF)
71-43-2 Benzene 78.11 1.4 7.1 45 0.02 0.14 0.56 42 Dense 4.4
86290-81-5 Gasoline 94.98 1.1 6.7 41 0.05 0.16 0.68 34 Dense 5.1
110-82-7 Cyclohexane 84.16 1.3 8.0 45 0.02 0.14 0.63 37 Dense 4.9
107-06-2 Ethylene dichloride 98.96 6.2 16.0 250 0.02 0.16 0.39 60 Dense 1.4
100-41-4 Ethylbenzene 106.2 1.0 6.7 43 0.0025 0.14 0.56 42 Dense 4.2
8006-14-2 Natural gas liquefieda 16.04 5.0 15.0 33 N/A 0.15 1.1 Buoyant 5.6
8030-30-6 Naphthab 94.98 1.1 6.7 41 0.05 0.16 0.68 34 Dense 4.1
75-18-3 Dimethyl sulfide 62.1 2.2 19.7 56 0.09 0.13 0.57 41 Dense 4.5
75-64-9 t-Butylamine 73.1 1.7 8.9 51 0.07 0.14 0.71 33 Dense 4.5
108-88-3 Toluene 92.14 1.2 7.1 45 0.01 0.14 0.56 42 Dense 4.3
1330-20-7 Xylenes 106.2 1.1 7.0 48 0.0022 0.14 0.56 42 Dense 4.2
Equations:
LFB = 0.284 x (molecular weight)2/3 x 760 / (82.05 x boiling point (K))
DF = 1 / (density (lb / ft3 ) x 0.033)
LLF = 132.2 x 6.4516 E-4 x 0.1594 x 0.8 x (2 x 9.8)1/2 x liquid density (kg/m3)
PFF = heat of combustion (J/kg) x (0.0001 / (5000 x π [heat of vaporization (J/kg) + (specific heat (J/kg) x (boiling point (K) - 298))])1/2
PFF = HC x 0.0001
5000π x [ HV + CP (TB - 298) ]
Notes:
a = Same data as methane.
b = Same data as automotive gasoline.
N/A = not available
April 8, 2000

Annex 6
REFERENCE TABLE 1
Neutrally Buoyant Plume Distances to Toxic

Endpoint for Release Rate Divided by Endpoint
10-Minute Release, Rural Conditions, F Stability,
Wind Speed 1.5 Meters per Second
Release Rate/Endpoint Distance to Endpoint Release Rate/Endpoint Distance to Endpoint
[(lbs/min)/(mg/L)] (miles) [(lbs/min)/(mg/L)] (miles)
0 - 4.4 0.1 16,000 - 18,000 4.8

4.4 - 37 0.2 18,000 - 19,000 5.0
37 - 97 0.3 19,000 - 21,000 5.2
97 - 180 0.4 21,000 - 23,000 5.4
180 - 340 0.6 23,000 - 24,000 5.6
340 - 530 0.8 24,000 - 26,000 5.8
530 - 760 1.0 26,000 - 28,000 6.0
760 - 1,000 1.2 28,000 - 29,600 6.2
1,000 - 1,500 1.4 29,600 - 35,600 6.8
1,500 - 1,900 1.6 35,600 - 42,000 7.5
1,900 - 2,400 1.8 42,000 - 48,800 8.1
2,400 - 2,900 2.0 48,800 - 56,000 8.7
2,900 - 3,500 2.2 56,000 - 63,600 9.3
3,500 - 4,400 2.4 63,600 - 71,500 9.9
4,400 - 5,100 2.6 71,500 - 88,500 11
5,100 - 5,900 2.8 88,500 - 107,000 12
5,900 - 6,800 3.0 107,000 - 126,000 14
6,800 - 7,700 3.2 126,000 - 147,000 15
7,700 - 9,000 3.4 147,000 - 169,000 16
9,000 - 10,000 3.6 169,000 - 191,000 17
10,000 - 11,000 3.8 191,000 - 215,000 19
11,000 - 12,000 4.0 215,000 - 279,000 22
12,000 - 14,000 4.2 279,000 - 347,000 25
14,000 - 15,000 4.4 >347,000 >25*
15,000 - 16,000 4.6
*Report distance as 25 miles

Annex 6
REFERENCE TABLE 2
Neutrally Buoyant Plume Distances to Toxic Endpoint for

Release Rate Divided by Endpoint
60-Minute Release, Rural Conditions,
F Stability, Wind Speed 1.5 Meters per Second
0 - 5.5 0.1 7,400 - 7,700 4.8

5.5 - 46 0.2 7,700 - 8,100 5.0
46 - 120 0.3 8,100 - 8,500 5.2
120 - 220 0.4 8,500 - 8,900 5.4
220 - 420 0.6 8,900 - 9,200 5.6
420 - 650 0.8 9,200 - 9,600 5.8
650 - 910 1.0 9,600 - 10,000 6.0
910 - 1,200 1.2 10,000 - 10,400 6.2
1,200 - 1,600 1.4 10,400 - 11,700 6.8
1,600 - 1,900 1.6 11,700 - 13,100 7.5
1,900 - 2,300 1.8 13,100 - 14,500 8.1
2,300 - 2,600 2.0 14,500 - 15,900 8.7
2,600 - 2,900 2.2 15,900 - 17,500 9.3
2,900 - 3,400 2.4 17,500 - 19,100 9.9
3,400 - 3,700 2.6 19,100 - 22,600 11
3,700 - 4,100 2.8 22,600 - 26,300 12
4,100 - 4,400 3.0 26,300 - 30,300 14
4,400 - 4,800 3.2 30,300 - 34,500 15
4,800 - 5,200 3.4 34,500 - 38,900 16
5,200 - 5,600 3.6 38,900 - 43,600 17
5,600 - 5,900 3.8 43,600 - 48,400 19
5,900 - 6,200 4.0 48,400 - 61,500 22
6,200 - 6,700 4.2 61,500 - 75,600 25
6,700 - 7,000 4.4 >75,600 >25*
7,000 - 7,400 4.6
310 Guide de gestion des risques d’accidents industriels majeurs

Annex 6
REFERENCE TABLE 3
Neutrally Buoyant Plume Distances to Toxic Endpoint

for Release Rate Divided by Endpoint
10-Minute Release, Urban Conditions, F Stability,

0 - 21 0.1 76,000 - 83,000 4.8

21 - 170 0.2 83,000 - 90,000 5.0
170 - 420 0.3 90,000 - 100,000 5.2
420 - 760 0.4 100,000 - 110,000 5.4
760 - 1,400 0.6 110,000 - 120,000 5.6
1,400 - 2,100 0.8 120,000 - 130,000 5.8
2,100 - 3,100 1.0 130,000 - 140,000 6.0
3,100 - 4,200 1.2 140,000 - 148,000 6.2
4,200 - 6,100 1.4 148,000 - 183,000 6.8
6,100 - 7,800 1.6 183,000 - 221,000 7.5
7,800 - 9,700 1.8 221,000 - 264,000 8.1
9,700 - 12,000 2.0 264,000 - 310,000 8.7
12,000 - 14,000 2.2 310,000 - 361,000 9.3
14,000 - 18,000 2.4 361,000 - 415,000 9.9
18,000 - 22,000 2.6 415,000 - 535,000 11
22,000 - 25,000 2.8 535,000 - 671,000 12
25,000 - 29,000 3.0 671,000 - 822,000 14
29,000 - 33,000 3.2 822,000 - 990,000 15
33,000 - 39,000 3.4 990,000 - 1,170,000 16
39,000 - 44,000 3.6 1,170,000 - 1,370,000 17
44,000 - 49,000 3.8 1,370,000 - 1,590,000 19
49,000 - 55,000 4.0 1,590,000 - 2,190,000 22
55,000 - 63,000 4.2 2,190,000 - 2,890,000 25
63,000 - 69,000 4.4 >2,890,000 >25*
69,000 - 76,000 4.6

Annex 6
REFERENCE TABLE 4

60-Minute Release, Urban Conditions, F Stability,
0 - 26 0.1 34,000 - 36,000 4.8

26 - 210 0.2 36,000 - 38,000 5.0
210 - 530 0.3 38,000 - 41,000 5.2
530 - 940 0.4 41,000 - 43,000 5.4
940 - 1,700 0.6 43,000 - 45,000 5.6
1,700 - 2,600 0.8 45,000 - 47,000 5.8
2,600 - 3,700 1.0 47,000 - 50,000 6.0
3,700 - 4,800 1.2 50,000 - 52,200 6.2
4,800 - 6,400 1.4 52,200 - 60,200 6.8
6,400 - 7,700 1.6 60,200 - 68,900 7.5
7,700 - 9,100 1.8 68,900 - 78,300 8.1
9,100 - 11,000 2.0 78,300 - 88,400 8.7
11,000 - 12,000 2.2 88,400 - 99,300 9.3
12,000 - 14,000 2.4 99,300 - 111,000 9.9
14,000 - 16,000 2.6 111,000 - 137,000 11
16,000 - 17,000 2.8 137,000 - 165,000 12
17,000 - 19,000 3.0 165,000 - 197,000 14
19,000 - 21,000 3.2 197,000 - 232,000 15
21,000 - 23,000 3.4 232,000 - 271,000 16
23,000 - 24,000 3.6 271,000 - 312,000 17
24,000 - 26,000 3.8 312,000 - 357,000 19
26,000 - 28,000 4.0 357,000 - 483,000 22
28,000 - 30,000 4.2 483,000 - 629,000 25
30,000 - 32,000 4.4 >629,000 >25*
32,000 - 34,000 4.6 *Report distance as 25 miles

REFERENCE TABLE 5
Dense Gas Distances to Toxic Endpoint
Toxic Endpoint (mg/L)
Release
Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
min) Distance (Miles)
1 2.2 1.7 1.5 1.1 0.8 0.7 0.5 0.5 0.3 0.2 0.2 0.2 0.1 0.1 # #
2 3.0 2.4 2.1 1.5 1.1 0.9 0.7 0.7 0.4 0.3 0.3 0.2 0.2 0.1 <0.1 <0.1
5 4.8 3.7 3.0 2.2 1.7 1.5 1.2 1.0 0.7 0.5 0.4 0.3 0.3 0.2 0.1 0.1
10 6.8 5.0 4.2 3.0 2.4 2.1 1.7 1.4 1.0 0.7 0.6 0.5 0.4 0.2 0.2 0.1
30 11 8.7 6.8 5.2 3.9 3.4 2.8 2.4 1.7 1.3 1.1 0.9 0.7 0.4 0.3 0.2
50 14 11 9.3 6.8 5.0 4.2 3.5 3.0 2.2 1.7 1.4 1.1 0.9 0.6 0.4 0.3
100 19 15 12 8.7 6.8 5.8 4.8 4.2 2.9 2.2 1.9 1.6 1.3 0.8 0.5 0.4
150 24 18 15 11 8.1 6.8 5.7 5.0 3.6 2.7 2.3 1.9 1.6 0.9 0.6 0.5
250 >25 22 19 14 11 8.7 7.4 6.2 4.5 3.4 2.8 2.3 2.0 1.2 0.8 0.6
500 * >25 >25 19 14 12 9.9 8.7 6.2 4.7 3.8 3.1 2.7 1.6 1.1 0.9

750 * * * 23 17 15 12 11 7.4 5.5 4.5 3.7 3.2 1.9 1.3 1.0
1,000 * * * >25 20 17 14 12 8.1 6.2 5.2 4.2 3.6 2.2 1.4 1.1
1,500 * * * * 24 20 16 14 9.9 7.4 6.2 5.0 4.3 2.5 1.7 1.3
2,000 * * * * >25 23 19 16 11 8.7 6.8 5.6 4.8 2.9 1.9 1.5
2,500 * * * * * >25 20 18 12 9.3 8.1 6.2 5.3 3.2 2.1 16
3,000 * * * * * * 23 20 14 9.9 8.7 6.8 5.6 3.4 2.2 1.7
4,000 * * * * * * >25 22 16 11 9.3 7.4 6.2 3.8 2.5 2.0
5,000 * * * * * * * 25 17 13 11 8.7 6.8 4.2 2.7 2.1
7,500 * * * * * * * >25 20 15 12 9.9 8.7 4.9 3.2 2.5
10,000 * * * * * * * * 24 17 14 11 9.3 5.5 3.6 2.8
15,000 * * * * * * * * >25 20 17 13 11 6.2 4.2 3.2
20,000 * * * * * * * * * 23 19 15 12 7.4 4.7 3.7
50 000 * * * * * * * * * >25 >25 21 18 10 6.6 5.0
75,000 * * * * * * * * * * * >25 21 12 7.6 5.8
100,000 * * * * * * * * * * * * 24 13 8.5 6.4
150,000 * * * * * * * * * * * * >25 15 9.8 7.4
200,000 * * * * * * * * * * * * * 17 11 8.2
Annex 6
* > 25 miles (report distance as 25 miles)

# <0.1 mile (report distance as 0.1 mile)
313
314
REFERENCE TABLE 6
Annex 6

Release Toxic Endpoint (mg/L)
Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 3.7 2.7 2.2 1.4 1.0 0.8 0.6 0.5 0.3 0.2 0.2 0.1 0.1 <0.1 # #
2 5.3 4.0 3.2 2.2 1.6 1.2 1.0 0.8 0.5 0.4 0.3 0.2 0.2 0.1 <0.1 <0.1
5 8.7 6.8 5.3 3.7 2.7 2.2 1.7 1.4 0.9 0.6 0.5 0.4 0.3 0.2 0.1 0.1
10 12 9.3 8.1 5.3 4.0 3.3 2.7 2.2 1.4 1.0 0.8 0.6 0.5 0.3 0.2 0.1
30 22 16 14 9.9 7.4 6.1 4.9 4.1 2.9 2.1 1.6 1.2 1.0 0.5 0.3 0.2
50 >25 21 18 12 9.3 8.1 6.2 5.4 3.8 2.7 2.2 1.7 1.4 0.7 0.4 0.3
100 * >25 >25 18 13 11 9.3 7.4 5.5 4.0 3.2 2.5 2.1 1.1 0.7 0.5
150 * * * 22 17 14 11 9.9 6.8 4.9 4.0 3.1 2.7 1.4 0.9 0.6
250 * * * >25 22 18 14 12 8.7 6.2 5.2 4.1 3.5 1.9 1.2 0.9
500 * * * * >25 25 20 17 12 9.3 7.4 5.8 5.0 2.9 1.8 1.3
750 * * * * * >25 25 22 15 11 9.3 7.4 6.1 3.5 2.2 1.7
1,000 * * * * * * >25 25 17 12 11 8.1 6.8 4.0 2.6 2.0
1,500 * * * * * * * >25 20 16 12 9.9 8.7 5.0 3.2 2.5
2,000 * * * * * * * * 24 17 14 11 9.9 5.7 3.7 2.9
2,500 * * * * * * * * >25 20 16 13 11 6.2 4.2 3.2
3,000 * * * * * * * * * 21 17 14 12 6.8 4.5 3.5
4,000 * * * * * * * * * 24 20 16 14 8.1 5.2 4.0
5,000 * * * * * * * * * >25 22 17 15 8.7 5.7 4.4
7,500 * * * * * * * * * * >25 21 18 11 6.8 5.2
10,000 * * * * * * * * * * * 24 20 12 7.4 6.0
15,000 * * * * * * * * * * * >25 24 14 9.3 6.8
20,000 * * * * * * * * * * * * >25 16 9.9 8.1

50,000 * * * * * * * * * * * * * 22 14 11
75,000 * * * * * * * * * * * * * >25 17 13
100,000 * * * * * * * * * * * * * * 18 14
150,000 * * * * * * * * * * * * * * 21 16
200,000 * * * * * * * * * * * * * * 23 18
REFERENCE TABLE 7
10-Minute Release, Urban Conditions,
Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 1.6 1.2 1.1 0.7 0.6 0.4 0.4 0.3 0.2 0.2 0.1 0.1 0.1 # # #
2 2.2 1.7 1.4 1.1 0.8 0.6 0.5 0.4 0.3 0.2 0.2 0.1 0.1 <0.1 # #
5 3.5 2.7 2.2 1.6 1.2 1.0 0.8 0.7 0.5 0.4 0.3 0.2 0.2 0.1 <0.1 #
10 4.9 3.8 3.1 2.2 1.7 1.4 1.2 1.0 0.7 0.5 0.4 0.3 0.2 0.1 <0.1 0.1
30 8.1 6.2 5.3 3.7 2.9 2.4 2.0 1.7 1.2 0.9 0.7 0.6 0.4 0.2 0.1 0.1
50 11 8.1 6.8 4.8 3.7 3.1 2.5 2.1 1.5 1.1 0.9 0.7 0.6 0.3 0.2 0.1
100 15 11 9.3 6.8 5.2 4.2 3.5 3.0 2.1 1.6 1.3 1.0 0.9 0.5 0.3 0.2
150 19 14 12 8.1 6.1 5.2 4.3 3.6 2.5 1.9 1.6 1.2 1.1 0.6 0.4 0.2
250 24 18 15 11 8.1 6.8 5.4 4.6 3.3 2.4 2.0 1.6 1.4 0.7 0.5 0.3
500 >25 >25 21 15 11 9.3 7.4 6.2 4.5 3.4 2.8 2.2 1.9 1.1 0.7 0.5
750 * * >25 18 14 11 9.3 8.1 5.5 4.1 3.3 2.6 2.2 1.3 0.8 0.6

1,000 * * * 21 16 13 11 9.3 6.2 4.6 3.8 3.0 2.5 1.5 0.9 0.7
1,500 * * * >25 19 16 12 11 7.4 5.6 4.6 3.7 3.0 1.7 1.1 0.8
2,000 * * * * 22 18 15 12 8.7 6.2 5.2 4.1 3.5 2.0 1.3 0.9
2,500 * * * * 24 20 16 14 9.9 6.8 5.8 4.7 3.8 2.2 1.4 1.1
3,000 * * * * >25 22 18 16 11 7.4 6.2 5.0 4.2 2.4 1.6 1.2
4,000 * * * * * 25 20 17 12 8.7 6.8 5.6 4.8 2.7 1.7 1.3
5,000 * * * * * >25 23 20 14 9.9 8.1 6.2 5.3 3.0 1.9 1.4
7,500 * * * * * * >25 24 16 12 9.9 7.4 6.2 3.6 2.3 1.7
10,000 * * * * * * * >25 19 14 11 8.7 7.4 4.1 2.6 2.0
15,000 * * * * * * * * 22 16 13 11 8.7 4.9 3.1 2.3
20,000 * * * * * * * * >25 19 15 12 9.9 5.5 3.5 2.7
50,000 * * * * * * * * * >25 23 17 15 8.1 5.1 38
75,000 * * * * * * * * * * >25 21 17 9.6 6.0 4.5
100,000 * * * * * * * * * * * 24 20 11 6.8 5.1
150,000 * * * * * * * * * * * >25 23 13 8.1 6.1
200,000 * * * * * * * * * * * * >25 14 8.9 6.7
Annex 6
* >25 miles (report distance as 25 miles)

315
316
REFERENCE TABLE 8
Annex 6

Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 2.6 1.9 1.5 1.1 0.7 0.6 0.4 0.4 0.2 0.2 0.1 0.1 0.1 # # #
2 3.8 2.9 2.3 1.5 1.1 0.9 0.7 0.6 0.4 0.2 0.2 0.1 0.1 <0.1 # #
5 6.2 4.7 3.9 2.6 1.9 1.5 1.2 0.9 0.6 0.4 0.3 0.2 0.2 0.1 <0.1 #
10 9.3 6.8 5.6 3.9 2.9 2.3 1.8 1.5 0.9 0.7 0.5 0.4 0.3 0.2 0.1 <0.1
30 16 12 9.9 7.4 5.3 4.3 3.4 2.9 1.9 1.3 1.0 0.7 0.6 0.3 0.2 0.1
50 22 16 14 9.3 6.8 5.7 4.5 3.8 2.6 1.8 1.4 1.1 0.9 0.4 0.2 0.2
100 >25 24 20 14 9.9 8.1 6.8 5.7 3.8 2.7 2.2 1.7 1.4 0.7 0.4 0.3
150 * >25 24 17 12 11 8.1 6.8 4.8 3.5 2.8 2.2 1.8 0.9 0.5 0.3
250 * * >25 22 16 14 11 9.3 6.2 4.5 3.7 2.9 2.4 1.2 0.7 0.5
500 * * * >25 24 19 16 13 9.3 6.8 5.4 4.2 3.5 1.9 1.1 0.7
750 * * * * >25 24 19 16 11 8.1 6.8 5.2 4.3 2.4 1.4 1.0
1,000 * * * * * >25 22 19 13 9.3 7.4 6.0 5.0 2.8 1.6 1.2
1,500 * * * * * * >25 24 16 12 9.3 7.4 6.2 3.4 2.1 1.5
2,000 * * * * * * * >25 19 13 11 8.7 7.4 4.0 2.5 1.8
2,500 * * * * * * * * 20 15 12 9.3 8.1 4.5 2.8 2.1
3,000 * * * * * * * * 22 16 13 11 8.7 4.9 3.0 2.2
4,000 * * * * * * * * >25 19 16 12 9.9 5.6 3.5 2.6
5,000 * * * * * * * * * 21 17 14 11 6.2 4.0 3.0
7,500 * * * * * * * * * >25 20 16 14 7.4 48 3.6
10,000 * * * * * * * * * * 24 19 16 8.7 5.5 4.2
15,000 * * * * * * * * * * >25 22 19 11 6.8 5.1
20,000 * * * * * * * * * * * >25 21 12 7.4 5.8
50,000 * * * * * * * * * * * * >25 18 11 8.7

75,000 * * * * * * * * * * * * * 21 13 10
100,000 * * * * * * * * * * * * * 24 15 11
150,000 * * * * * * * * * * * * * >25 18 14
200,000 * * * * * * * * * * * * * * 20 15
* > 25 miles (report distance as 25 miles)

Annex 6
REFERENCE TABLE 9
Distances to Toxic Endpoint for Anhydrous
Ammonia Liquefied Under Pressure
Release Rate Distance to Endpoint (miles) Release Rate Distance to Endpoint (miles)
(lbs/min) Rural Urban (lbs/min) Rural Urban
1 0.1 <0.1* 1,000 1.8 1.2
2 0.1 0.1 1,500 2.2 1.5
5 0.1 0.1 2,000 2.6 1.7
10 0.2 0.1 2,500 2.9 1.9
15 0.2 0.2 3,000 3.1 2.0
20 0.3 0.2 4,000 3.6 2.3
30 0.3 0.2 5,000 4.0 2.6
40 0.4 0.3 6,000 4.4 2.8
50 0.4 0.3 7,000 4.7 3.1
60 0.5 0.3 7,500 4.9 3.2
70 0.5 0.3 8,000 5.1 3.3
80 0.5 0.4 9,000 5.4 3.4
90 0.6 0.4 10,000 5.6 3.6
100 0.6 0.4 15,000 6.9 4.4
150 0.7 0.5 20,000 8.0 5.0
200 0.8 0.6 25,000 8.9 5.6
250 0.9 0.6 30,000 9.7 6.1
300 1.0 0.7 40,000 11 7.0
400 1.2 0.8 50,000 12 7.8
500 1.3 0.9 75,000 15 9.5
600 1.4 0.9 100,000 18 10
700 1.5 1.0 150,000 22 13
750 1.6 1.0 200,000 ** 15
800 1.6 1.1 250,000 ** 17
900 1.7 1.2 750,000 ** **
* Report distance as 0.1 mile

** More than 25 miles (report distance as 25 miles)

Annex 6
REFERENCE TABLE 10
Distances to Toxic Endpoint for Non-liquefied Ammonia,
Ammonia Liquefied by Refrigeration,
or Aqueous Ammonia
1 0.1 2,500 2.5 0.9
2 0.1 <0.1* 3,000 2.7 1.0
5 0.1 4,000 3.1 1.1
10 0.2 0.1 5,000 3.4 1.2
15 0.2 0.1 6,000 3.7 1.3
20 0.3 0.1 7,000 4.0 1.4
30 0.3 0.1 7,500 4.1 1.5
40 0.4 0.1 8,000 4.2 1.5
50 0.4 0.1 9,000 4.5 1.6
60 0.4 0.2 10,000 4.7 1.7
70 0.5 0.2 15,000 5.6 2.0
80 0.5 0.2 20,000 6.5 2.4
90 0.5 0.2 25,000 7.2 2.6
100 0.6 0.2 30,000 7.8 2.8
150 0.7 0.2 40,000 8.9 3.3
200 0.8 0.3 50,000 9.8 3.6
250 0.8 0.3 75,000 12 4.4
300 0.9 0.3 100,000 14 5.0
400 1.1 0.4 150,000 16 6.1
500 1.2 0.4 200,000 19 7.0
600 1.3 0.4 250,000 21 7.8
700 1.4 0.5 750,000 ** 13
750 1.4 0.5
* Report distance as 0.1 mile
800 1.5 0.5 ** More than 25 miles (report distance as 25 miles)
900 1.5 0.6

Annex 6
REFERENCE TABLE 11
Distances to Toxic Endpoint for Chlorine
1 0.2 0.1 750 5.8 2.6
2 0.3 0.1 800 5.9 2.7
5 0.5 0.2 900 6.3 2.9
10 0.7 0.3 1,000 6.6 3.0
10 0.7 0.3 1,500 8.1 3.8
15 0.8 0.4 2,000 9.3 4.4
20 1.0 0.4 2,500 10 4.9
30 1.2 0.5 3,000 11 5.4
40 1.4 0.6 4,000 13 6.2
50 1.5 0.6 5,000 14 7.0
60 1.7 0.7 6,000 16 7.6
70 1.8 0.8 7,000 17 8.3
80 1.9 0.8 7,500 18 8.6
90 2.0 0.9 8,000 18 8.9
100 2.2 0.9 9,000 19 9.4
150 2.6 1.2 10,000 20 9.9
200 3.0 1.3 15,000 25 12
250 3.4 1.5 20,000 * 14
300 3.7 1.6 25,000 * 16
400 4.2 1.9 30,000 * 18
500 4.7 2.1 40,000 * 20
500 4.7 2.1 50,000 * *
600 5.2 2.3
* More than 25 miles (report distance as 25 miles)
700 5.6 2.5

Annex 6
REFERENCE TABLE 12
Distances to Toxic Endpoint for Anhydrous Sulfur Dioxide

1 0.2 0.1 750 6.6 2.6
2 0.2 0.1 800 6.8 2.7
5 0.4 0.2 900 7.2 2.9
10 0.6 0.2 1,000 7.7 3.1
15 0.7 0.3 1,500 9.6 3.8
20 0.9 0.4 2,000 11 4.5
30 1.1 0.5 2,500 13 5.0
40 1.3 0.5 3,000 14 5.6
50 1.4 0.6 4,000 17 6.5
60 1.6 0.7 5,000 19 7.3
70 1.8 0.7 6,000 21 8.1
80 1.9 0.8 7,000 23 8.8
90 2.0 0.8 7,500 24 9.1
100 2.1 0.9 8,000 25 9.5
150 2.7 1.1 9,000 * 10
200 3.1 1.3 10,000 * 11
250 3.6 1.4 15,000 * 13
300 3.9 1.6 20,000 * 16
400 4.6 1.9 25,000 * 18
500 5.2 2.1 30,000 * 19
600 5.8 2.3 40,000 * 23
700 6.3 2.5 50,000 * *
* More than 25 miles (report distance as 25 miles)

REFERENCE TABLE 13
Distance to Overpressure of 1.0 psi for Vapor Cloud

Explosions of 500 - 2,000,000 Pounds of Regulated Flammable Substances
Based on TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud (pounds) 500 2,000 5,000 10,000 20,000 50,000 100,000 200,000 500,000 1,000,000 2,000,000
CAS No. Chemical Name Distance (Miles) to 1 psi Overpressure
75-07-0 Acetaldehyde 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.7 0.8
74-86-2 Acetylene 0.07 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.7 0.8 1.0
598-73-2 Bromotrifluoroethylene 0.02 0.04 0.05 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4
106-99-0 1,3-Butadiene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
106-97-8 Butane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0

25167-67 3-Butene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
590-18-1 2-Butene-cis 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
624-64-6 2-Butene-trans 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
106-98-9 1-Butene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
107-01-7 2-Butene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
463-58-1 Carbon oxysulfide 0.04 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6
7791-21-1 Chlorine monoxide 0.02 0.03 0.04 0.05 0.06 0.08 0.1 0.1 0.2 0.2 0.3
590-21-6 1-Chloropropylene 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8
460-19-5 Cyanogen 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8
75-19-4 Cyclopropane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
4109-96-0 Dichlorosilane 0.04 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6
75-37-6 Difluoroethane 0.04 0.06 0.09 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6
124-40-3 Dimethylamine 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
463-82-1 2,2-Dimethylpropane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
74-84-0 Ethane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
107-00-6 Ethyl acetylene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
Annex 6
321
322
REFERENCE TABLE 13 — CONTINUED
Annex 6

75-04-7 Ethylamine 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
75-00-3 Ethyl chloride 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8
74-85-1 Ethylene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.7 0.8 1.0
60-29-7 Ethyl ether 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
75-08-1 Ethyl mercaptan 0.05 0.09 0.1 0.2 0.2 0.2 0.3 0.4 0.5 0.7 0.9
109-95-5 Ethyl nitrite 0.05 0.07 0.1 0.1 0.2 0.2 0.3 0.3 0.5 0.6 0.7
1333-74-0 Hydrogen 0.09 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.9 1.1 1.4
75-28-5 Isobutane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
78-79-5 Isoprene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
75-31-0 Isopropylamine 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
75-29-6 Isopropyl chloride 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8
74-82-8 Methane 0.07 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.7 0.8 1.0
74-89-5 Methylamine 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
563-45-1 3-Methyl-1-butene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
563-46-2 2-Methyl-1-butene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
115-10-6 Methyl ether 0.05 0.09 0.1 0.1 0.2 0.3 0.3 0.4 0.5 0.7 0.9
107-31-3 Methyl formate 0.04 0.07 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7
115-11-7 2-Methylpropene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
504-60-9 1,3-Pentadiene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
109-66-0 Pentane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
109-67-1 1-Pentene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0

REFERENCE TABLE 13 — END

646-04-8 2-Pentene, (E)- 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
627-20-3 2-Pentene, (Z)- 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
463 49-0 Propadiene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
74-98-6 Propane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
115-07-1 Propylene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0

74-99-7 Propyne 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
7803-62-5 Silane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
116-14-3 Tetrafluoroethylene 0.02 0.03 0.04 0.05 0.07 0.09 0.1 0.1 0.2 0.2 0.3
75-76-3 Tetramethylsilane 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
10025-78-2 Trichlorosilane 0.03 0.04 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.4
79-38-9 Trifluorochloroethylene 0.02 0.03 0.05 0.06 0.07 0.1 0.1 0.2 0.2 0.3 0.3
75-50-3 Trimethylamine 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.6 0.8 1.0
689-97-4 Vinyl acetylene 0.06 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8 1.0
75-01-4 Vinyl chloride 0.05 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6 0.8
109-92-2 Vinyl ethyl ether 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
75-02-5 Vinyl fluoride 0.02 0.04 0.05 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4
75-35-4 Vinylidene chloride 0.04 0.06 0.08 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6
75-38-7 Vinylidene fluoride 0.04 0.06 0.09 0.1 0.1 0.2 0.2 0.3 0.4 0.5 0.6
107-25-5 Vinyl methyl ether 0.06 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.6 0.7 0.9
Annex 6
323
324
REFERENCE TABLE 13A
Annex 6
Distance to Overpressure of 1psi for Vapor Cloud Explosions of Flammable Substances
71-43-2 Benzene 0.06 0.10 0.13 0.17 0.21 0.28 0.36 0.45 0.61 0.77 0.97
75-18-3 Dimethyl sulphide 0.05 0.09 0.12 0.15 0.19 0.25 0.2132 0.40 0.54 0.68 0.86
75-64-9 t-Butylamine 0.06 0.09 0.13 0.16 0,20 0.28 0.35 0.44 0.60 0.75 0.95
100-41-4 Ethylbenzene 0.06 0.10 0.13 0.17 0.21 0.29 0.36 0.45 0.61 0.77 0.98
107-06-2 Ethylenedichloride 0.04 0.06 0.09 0.11 0.14 0.19 0.23 0.29 0.40 0.50 0.63
108-88-3 Toluene 0.06 0.10 0.13 0.17 0.21 0.28 0.36 0.45 0.61 0.77 0.97
110-82-7 Cyclohexane 0.06 0.10 0.14 0.17 0.21 0.29 0.37 0.46 0.63 0.79 1.00
1330-20-7 Xylenes 0.06 0.10 0.13 0.17 0.21 0.29 0.36 0.45 0.61 0.77 0.97
8006-14-2 Natural gas 0.07 0.10 0.10 0.20 0.20 0.30 0.40 0.50 0.70 0.80 1.00
8030-30-6 Naphtha 0.06 0.10 0.14 0.17 0.21 0.29 0.37 0.46 0.63 0.79 1.00
86290-81-5 Gasoline 0.06 0.10 0.14 0.17 0.21 0.29 0.37 0.46 0.63 0.79 1.00
Equation:
D (miles) = 0.0081 x (0.1 x weight (lb) x (heat of combustion (kJ/kg) / heat of explosion of TNT (4 680 kJ / kg))1/3
1/3
HCf
Equation C-2: Dmi = 0.0081 x 0.1 x Wlb x
{ HCTNT }
March 7, 2000

Annex 6
Symbols used in calculating the worst-case scenario
A = Area of the diked liquid pool (square feet);

also area of building floor (square feet)
Amax = Maximum area of a liquid pool of 1-cm thickness
(square feet)
D = Distance to overpressure of 1 psi (meters)
DF = Density factor
HCf Heat of combustion of flammable substance (kilojoules/kilogram)
HCm = Heat of combustion of mixture (kilojoules/kilogram)
HCTNT = Heat of combustion of TNT (4,680 kilojoules/kilogram)
HCx = Heat of combustion of component “x”
(kilojoules/kilogram)
HCy = Heat of combustion of component “y”
(kilojoules/kilogram)
L = Length of the building or structure (feet)
LFA = Liquid factor ambient temperature (25°C)
LFB = Liquid factor boiling (>25°C)
MWi = Molecular weight of each component of the mixture
Q10 min = Total quantity of the evaporated substance
during the first 10 minutes
QRB = Release rate from building B (pounds per minute)
QRc = Release rate corrected according to the temperature of the liquid
(pounds per minute)
t = Duration of release (minutes)
T = Temperature in Kelvin
TCF = Temperature correction factor
TNT = Trinitrotoluene (explosive)
U = Wind speed (meters per second)
VPm = Partial vapor pressure of the regulated substance in the mixture
(millimeters of mercury)
VPp = Vapor pressure of the pure regulated substance
at the same temperature as the mixture (mm Hg)
W = Width of the building or structure (feet)
Wf = Weight of flammable substance
Wi = Weight of each component of the mixture
Wm = Total weight of mixture (kilograms)
Wr = Weight of the regulated substance in the mixture
Wx = Weight of component “x” in the mixture (kilograms)
Wy = Weight of component “y” in the mixture (kilograms)
Xr = Moler fraction of the regulated substance (unitless)

Annex 6
Equations used in calculating the worst-case scenario
Equation . . . . . . .3-1 QR = QS
10
Equation . . . . . . .3-2 QR = QS x 0.55
10
Equation . . . . . . .3-3 QR = QS x 1.4 x LFA x DF
Equation . . . . . . .3-4 QR = QS x 1.4 x LFB x DF
Equation . . . . . . .3-5 t = QS
QR
Equation . . . . . . .3-6 A= QS x DF
Equation . . . . . . .3-7 QR = 1.4 x LFA x A
Equation . . . . . . .3-8 QR = 1.4 x LFB x A
Equation . . . . . . .3-9 A=LxW
Equation . . . . . .3-10 QRB = 0.1 x QR
Equation . . . . . .3-11 QRc = QR x TCF
Xr = n
{ } Wr
MWr
Equation . . . . . . .B-4
{ }
i=1
Wi
MWi
Equation . . . . . . .B-5 Xr =
{ } Wr
MWr
{ }{ }{ }
Wr
MWr
+
W1
MW1
+
W2
MW2
Equation . . . . . . .B-6 VPm = Xr x VPp
Equation . . . . . . .B-7 QR = 0.0035 x U0.78 x MW2/3 x A x VP

T
Equation . . . . . . . .16 Q10 min = QR x 10 minutes
Equation . . . . . . .C-1 D = 17 x (0.1 x Wf x HCf / HCTNT)1/3
Equation . . . . . . .C-2 Dmi = 0.0081 x (0.1 x Wlb x HCf / HCTNT)1/3
Equation . . . . . . .C-3 HCm = Wx / Wm x HCx + Wy / Wm x HCy

Determining Alternative
Release Scenarios:
Excerpts from the EPA Document
“Risk Management Program Guidance for Offsite
Consequence Analysis”
Annex
7 327
Note:
This annex consists of excerpts from Chapters 6, 7, 8, 9 and 10 of the EPA document “Risk
Management Program Guidance for Offsite Consequence Analysis.”
EPA based its calculations on a wind speed of 3 m/s and a D stability. CRAIM recommends the
use of the worst meteorological conditions (1.5 m/s and F stability) for the calculations.

Annex 7
6. Determining Alternative Release Scenarios

You are required to analyze at least one alternative release scenario for each listed toxic substance
you have in a Program 2 or Program 3 process above its threshold quantity. You also are required to
analyze one alternative release scenario for flammable substances in Program 2 or 3 processes as a
class (i.e., you analyze one scenario involving a flammable substance as a representative scenario for
all the regulated flammable substances you have on site in Program 2 or Program 3 processes). You
do not need to analyze an alternative scenario for each flammable substance. For example, if you
have five listed substances—chlorine, ammonia, hydrogen chloride, propane, and acetylene—above
the threshold in Program 2 or 3 processes, you will need to analyze one alternative scenario each
for chlorine, ammonia, and hydrogen chloride and a single alternative scenario to cover propane
and acetylene (listed flammable substances). Even if you have a substance above the threshold in
several processes or locations, you need only analyze one alternative scenario for it.
According to the rule (40 CFR 68.28), alternative scenarios should be more likely to occur than the
worst-case scenario and should reach an endpoint offsite, unless no such scenario exists. Release
scenarios considered should include, but are not limited to, the following:
• Transfer hose releases due to splits or sudden hose uncoupling;
• Process piping releases from failures at flanges, joints, welds, valves and valve seals, and
drains or bleeds;
• Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure;
• Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture
disks; and
• Shipping container mishandling or puncturing leading to a spill.
Alternative release scenarios for toxic substances should be those that lead to concentrations
above the toxic endpoint beyond your fenceline. Scenarios for flammable substances should
have the potential to cause substantial damage, including on-site damage. Those releases that
have the potential to reach the public are of the greatest concern. You should consider unusu-
al situations, such as start-up and shut-down, in selecting an appropriate alternative scenario.
For alternative release scenarios, you are allowed to consider active mitigation systems, such as
interlocks, shutdown systems, pressure relieving devices, flares, emergency isolation systems,
and fire water and deluge systems, as well as passive mitigation systems, as described in Sections
3.1.2 and 3.2.3.
For alternative release scenarios for regulated substances used in ammonia refrigeration, chem-
ical distribution, propane distribution, warehouses, or POTWs, consult EPA’s risk management
program guidance documents for these industry sectors.
You have a number of options for selecting release scenarios for toxic or flammable substances.
• You may use your worst-case release scenario and apply your active mitigation system to
limit the quantity released and the duration of the release.
• You may use information from your process hazards analysis, if you have conducted one, to
select a scenario.
• You may review your accident history and choose an actual event as the basis of your sce-
nario.
• If you have not conducted a process hazards analysis, you may review your operations and
identify possible events and failures.
Whichever approach you select, the key information you need to define is the quantity to be
released and the time over which it will be released; together, these allow you to estimate the
release rate and use essentially the same methods you used for the worst-case analysis.

Annex 7
For flammable substances, the choice of alternative release scenarios is somewhat more com-
plicated than for toxic substances, because the consequences of a release and the endpoint of
concern may vary. For the flammable worst case, the consequence of concern is a vapor cloud
explosion, with an overpressure endpoint. For alternative scenarios (e.g., fires), other endpoints
(e.g., heat radiation) may need to be considered.
Possible scenarios involving flammable substances include:
• Vapor cloud fires
Vapor cloud fires (flash fires) may result from dispersion of a cloud of flammable vapor and
ignition of the cloud following dispersion. Such a fire could flash back and could represent
a severe heat radiation hazard to anyone in the area of the cloud. This guidance provides
methods to estimate distances to a concentration equal to the lower flammability limit (LFL)
for this type of fire. (See Sections 9.1, 9.2, and 10.1.)
• Pool fire
A pool fire, with potential radiant heat effects, may result from a spill of a flammable liq-
uid. This guidance provides a simple method for estimating the distance from a pool fire to
a radiant heat level that could cause second degree burns from a 40-second exposure. (See
Section 10.2.)
• BLEVE
A boiling liquid, expanding vapor explosion (BLEVE), leading to a fireball that may produce
intense heat, may occur if a vessel containing flammable material ruptures explosively as a
result of exposure to fire. Heat radiation from the fireball is the primary hazard; vessel frag-
ments and overpressure from the explosion also can result. BLEVEs are generally considered
unlikely events; however, if you think a BLEVE is possible at your site, this guidance provides
a method to estimate the distance at which radiant heat effects might lead to second
degree burns. (See Section 10.3.) You also may want to consider models or calculation
methods to estimate effects of vessel fragmentation. (See Appendix A for references that
may provide useful information for estimating such effects.)
• Vapor cloud explosion
For a vapor cloud explosion to occur, rapid release of a large quantity, turbulent conditions
(caused by a turbulent release or congested conditions in the area of the release, or both), and
other factors are generally necessary. Vapor cloud explosions generally are considered unlike-
ly events; however, if conditions at your site are conducive to vapor cloud explosions, you may
want to consider a vapor cloud explosion as an alternative scenario. This guidance provides
methods you may use to estimate the distance to 1 psi overpressure for a vapor cloud deto-
nation, based on less conservative assumptions than the worst-case analysis. (See Section
10.4.) A vapor cloud deflagration, involving lower flame speeds than a detonation and result-
ing in less damaging blast effects, is more likely than a detonation. This guidance does not
provide methods for estimating the effects of a deflagration, but you may use other methods
of analysis if you want to consider such events. (See Appendix A for references that may pro-
vide useful information.)
• Jet fire
A jet fire may result from the puncture or rupture of a tank or pipeline containing a com-
pressed or liquefied gas under pressure. The gas discharging from the hole can form a jet
that “blows” into the air in the direction of the hole; the jet then may ignite. Jet fires could
contribute to BLEVEs and fireballs if they impinge on tanks of flammable substances. A
large horizontal jet fire may have the potential to pose an offsite hazard. This guidance does
not include a method for estimating consequence distances for jet fires. If you want to con-
sider a jet fire as an alternative scenario, you should consider other models or methods for
the consequence analysis. (See Appendix A for references that may provide useful informa-
tion.)

Annex 7
If you carry out an alternative scenario analysis for a flammable mixture (i.e., a mixture that
meets the criteria for NFPA 4), you need to consider all flammable components of the mixture,
not just the regulated flammable substance or substances in the mixture (see Section 5.2 on
flammable mixtures). If the mixture contains both flammable and non-flammable components,
the analysis should be carried out considering only the flammable components.
Chapter 7 provides detailed information on calculating release rates for alternative release sce-
narios for toxic substances. If you can estimate release rates for the toxic gases and liquids you
have on site based on readily available information, you may skip Chapter 7 and go to Chapter
8. Chapter 8 describes how to estimate distances to the toxic endpoint for alternative scenarios
for toxic substances. Chapter 9 provides information on calculating release rates for flammable
substances. Chapter 10 describes how to estimate distances to flammable endpoints.

Annex 7
7. Estimation of Release Rates

for Alternative Scenarios for Toxic Substances
7.1 Release Rates for Toxic Gases

7.1.1 Unmitigated Releases of Toxic Gases
Gaseous Releases
Gaseous Release from Tank
Instead of assuming release of the entire contents of a vessel containing a toxic gas, you may
decide to consider a more likely scenario as developed by the process hazards analysis, such as
release from a hole in a vessel or pipe. To estimate a hole size you might assume, for example,
the hole size that would result from shearing off a valve or pipe from a vessel containing a reg-
ulated substance. If you have a gas leak from a tank, you may use the following simplified equa-
tion to estimate a release rate based on hole size, tank pressure, and the properties of the gas.
This equation applies to choked flow, or maximum gas flow rate. Choked flow generally would
be expected for gases under pressure. (See Appendix D, Section D.6 for the derivation of this
equation.)
Equation 7-1: QR = HA x Pt 1 x GF
Tt
where:
HA = Hole or puncture area (square inches) (from hazard evaluation or best estimate)
Pt = Tank pressure (pounds per square inch absolute (psia)) (from process information;
for liquefied gases, equilibrium vapor pressure at 25°C is included in Exhibit B-1,
Appendix B)
Tt = Tank temperature (K), where K is absolute temperature in kelvins; 25°C (77°F) is 298 K
GF = Gas Factor, incorporating discharge coefficient, ratio of specific heats, molecular
weight, and conversion factors (listed for each regulated toxic gas in Exhibit B-1,
Appendix B)
You can estimate the hole area from the size and shape of the hole. For a circular hole, you
would use the formula for the area of a circle (area = r2, where is 3.14 and r is the radius of
the circle; the radius is half the diameter).
This equation will give an estimate of the initial release rate. It will overestimate the overall
release rate, because it does not take into account the decrease in the release rate as the pres-
sure in the tank decreases. You may use a computer model or another calculation method if you
want a more realistic estimate of the release rate. As discussed below, you may use this equa-
tion for releases of gases liquefied under pressure if the release would be primarily gas (e.g., if
the hole is in the head space of the tank, well above the liquid level).
Example 19: Release of Toxic Gas from Tank (Diborane)

You have a tank that contains diborane gas at a pressure of 30 psia. The temperature of the
tank and its contents is 298K (25ºC). A valve on the side of the tank shears off, leaving a cir-
cular hole 2 1/2 inches in diameter in the tank wall. You estimate the area from the formula
for area of a circle (r2, where r is the radius). The radius of the hole is 1 1/4 inches, so the
area is x (1 1/4)2 , or 5 square inches. From Exhibit B-1, the Gas Factor for diborane is 17.
Therefore, the release rate, from Equation 7-1, is:
QR = 5 x 30 x 1/(298)1/2 x 17 = 148 pounds per minute

Annex 7
Gaseous Release from Pipe

If shearing of a pipe may be an alternative scenario for a toxic gas at your site, you could use
the usual flow rate through the pipe as the release rate and carry out the estimation of distance
as discussed in Chapter 8.
If you want to consider a release of toxic gas through a hole in a pipe as an alternative scenario,
you may use the method described above for a gas release from a hole in a tank. This method
neglects the effects of friction along the pipe and, therefore, provides a conservative estimate
of the release rate.
Puff Releases
If a gaseous release from a hole in a tank or pipe is likely to be stopped very quickly (e.g., by a
block valve), resulting in a puff of toxic gas that forms a vapor cloud rather than a plume, you
may want to consider other methods for determining a consequence distance. A cloud of toxic
gas resulting from a puff release will not exhibit the same behavior as a plume resulting from a
longer release (e.g., a release over 10 minutes).
Liquefied Gases
Gases Liquefied Under Pressure
Gases liquefied under pressure may be released as gases, liquids, or a combination (two-phase),
depending on a number of factors, including liquid level and the location of the hole relative to
the liquid level. The resulting impact distances can vary greatly.
For releases from holes above the liquid level in a tank of gas liquefied under pressure, the
release could be primarily gas, or the release may involve rapid vaporization of a fraction of the
liquefied gas and possibly aerosolization (two-phase release). It is complex to determine which
type of release (i.e., gas, two-phase) will occur and the likely mix of gases and liquids in a two-
phase release. The methods presented in this guidance do not definitively address this situation.
As a rule of thumb, if the head space is large and the distance between the hole and the liquid
level is relatively large given the height of the tank or vessel, you could assume the release is
gaseous and, therefore, use Equation 7-1 above. (Exhibit B-1, Appendix B, includes the equilib-
rium vapor pressure in psia for listed toxic gases liquefied under pressure at 25°C; this pressure
can be used in Equation 7-1.) However, use of this equation will not be conservative if the head-
space is small and the release from the hole is two-phased. In situations where you are unsure
of whether the release would be gaseous or two-phase, you may want to consider other mod-
els or methods to carry out a consequence analysis.
For a hole in the liquid space of a tank, you may use Equation 7-2 below to estimate the release
rate. Exhibit B-1 in Appendix B gives the equilibrium vapor pressure in psia for listed toxic gases
at 25°C; this is the pressure required to liquefy the gas at this temperature. You can estimate
the gauge pressure in the tank from the equilibrium vapor pressure by subtracting the pressure
of the ambient atmosphere (14.7 psi). Exhibit B-1 also gives the Density Factor (DF) for each toxic
gas at its boiling point. This factor can be used to estimate the density of the liquefied gas (the
density at 25°C would not be significantly different from the density at the boiling point for most
of the listed gases). The equation to estimate the release rate is (see Appendix D, Section D.7.1,
for more information):

Annex 7
Equation 7-2: QR = HA x 6.82 11.7 x LH + 669 x Pg

DF2 DF
where:
DF = Density Factor (listed for each regulated toxic gas in Exhibit B-1, Appendix B;
1/(DF x 0.033) is density in pounds per cubic foot)
LH = Height of liquid column above hole (inches) (from hazard evaluation or best estimate)
Pg = Gauge pressure of the tank pressure (pounds per square inch gauge (psig)), from
vapor pressure of gas (listed in Exhibit B-1, Appendix B) minus atmospheric pressure
(14.7 psi)
This equation gives the rate of release of liquid through the hole. For a gas liquefied under pres-
sure, assume that the released liquid will immediately flash into vapor (or a vapor/aerosol mix-
ture) and the release rate to air is the same as the liquid release rate. This equation gives an esti-
mate of the initial release rate. It will overestimate the overall release rate, because it does not
take into account the decrease in the release rate as the pressure in the tank and the height of
the liquid in the tank decrease. You may use a computer model or another calculation method
if you want a more realistic estimate of the release rate.
For a release from a broken pipe of a gas liquefied under pressure, see Equations 7-4 to 7-6
below for liquid releases from pipes. Assume the released liquid flashes into vapor upon release
and use the calculated release rate as the release rate to air.
Gases Liquefied by Refrigeration
Gases liquefied by refrigeration alone may be treated as liquids. You may use the methods
described in Section 7.2 for estimation of release rates.
Duration of Release
The duration of the release is used in choosing the appropriate generic reference table of dis-
tances, as discussed in Chapter 8. (You do not need to consider the duration of the release to
use the chemical-specific reference tables.) You may calculate the maximum duration by divid-
ing the quantity in the tank or the quantity that may be released from pipes by your calculated
release rate. You may use 60 minutes as a default value for maximum release duration. If you
know, and can substantiate, how long it is likely to take to stop the release, you may use that
time as the release duration.
7.1.2 Mitigated Releases of Toxic Gases
For gases, passive mitigation may include enclosed spaces, as discussed in Section 3.1.2. Active
mitigation for gases, which may be considered in analyzing alternative release scenarios, may
include an assortment of techniques including automatic shutoff valves, rapid transfer systems
(emergency deinventory), and water/chemical sprays. These mitigation techniques have the
effect of reducing either the release rate or the duration of the release, or both.
Active Mitigation
Active Mitigation to Reduce Release Duration
An example of a mitigation technique to reduce the release duration is automatic shutoff valves.
If you have an estimate of the rate at which the gas will be released and the time it will take to
shut off the release, you may estimate the quantity potentially released (release rate times time).

Annex 7
You must be able to substantiate the time it will take to shut off the release. If the release will
take place over a period of 10 minutes or more, you may use the release rate to estimate the
distance to the toxic endpoint, as discussed in Chapter 8. For releases stopped in less than 10
minutes, multiply the initial release rate by the duration of release to estimate the quantity
released, then divide the new quantity by 10 minutes to estimate a mitigated release rate that
you may apply to the reference tables described in Chapter 8 to estimate the consequence dis-
tance. If the release would be stopped very quickly, you might want to consider other methods
that will estimate consequence distances for a puff release.
Active Mitigation to Directly Reduce Release Rate to Air
Examples of mitigation techniques to directly reduce the release rate include scrubbers and
flares. Use test data, manufacturer design specifications, or past experience to determine the
fractional reduction of the release rate by the mitigation technique. Apply this fraction to the
release rate that would have occurred without the mitigation technique. The initial release rate,
without mitigation, may be the release rate for the alternative scenario (e.g., a release rate esti-
mated from the equations presented earlier in this section) or the worst-case release rate. The
mitigated release rate is:
Equation 7-3: QRR = (1 - FR) x QR

where:
QRR = Reduced release rate (pounds per minute)
FR = Fractional reduction resulting from mitigation
QR = Release rate without mitigation (pounds per minute)
Example 20: Water Spray Mitigation (Hydrogen Fluoride)

A bleeder valve on a hydrogen fluoride (HF) tank opens, releasing 660 pounds per minute of
HF. Water sprays are applied almost immediately. Experimental field and laboratory test data
indicate that HF vapors could be reduced by 90 percent. The reduced release rate is:
QRR = (1 - 0.9) x (660 pounds per minute)
= 66 pounds per minute
In estimating the consequence distance for this release scenario, you would need to consider
the release both before and after application of the water spray and determine which gives
the greatest distance to the endpoint.
You need to be able to substantiate the time needed to begin the water spray mitigation.
Passive Mitigation
The same simplified method used for worst-case releases may be used for alternative release
scenarios to estimate the release rate to the outside air from a release in an enclosed space. For
alternative scenarios, you may use a modified release quantity, if appropriate. You may also
adjust the mitigation factor to account for the effects of ventilation, if appropriate for the alter-
native scenario you have chosen. Use the equations presented in Section 3.1.2 to estimate the
release rate to the outside air.
Duration of Release
You should estimate the duration of the release either from your knowledge of the length of
time it may take to stop the release (be prepared to substantiate your time estimate) or by divid-
ing the quantity that may be released by your estimated release rate. (You do not need to con-
sider the release duration to use the chemical-specific reference tables of distances.)

Annex 7
7.2 Release Rates for Toxic Liquids

This section describes methods for estimating liquid release rates from tanks and pipes. The
released liquid is assumed to form a pool, and the evaporation rate from the pool is estimated
as for the worst-case scenario. For the alternative scenario, you may assume the average wind
speed in your area in the calculation of evaporation rate, instead of the worst-case wind speed
of 1.5 meters per second (3.4 miles per hour). For the reference tables in this guidance, the wind
speed for alternative scenarios is assumed to be 3.0 meters per second (6.7 miles per hour).
If you have sufficient information to estimate the quantity of liquid that might be released to an
undiked area under an alternative scenario, you may go directly to Section 7.2.3 to estimate the
evaporation rate from the pool and the release duration. After you have estimated the evapo-
ration rate and release duration, go to Chapter 8 for instructions on estimating distance to the
toxic endpoint.
7.2.1 Liquid Release Rate and Quantity Released
for Unmitigated Releases
Release from Tank
Tank under Atmospheric Pressure
If you have a liquid stored in a tank at atmospheric pressure (including gases liquefied by refrig-
eration alone), you may use the following simple equation to estimate the liquid release rate
from a hole in the tank below the liquid level. (See Appendix D, Section D.7.1, for the deriva-
tion of this equation.)
Equation 7-4: QRL = HA x LH x LLF
where:
QRL = Liquid release rate (pounds per minute)
LH = Height of liquid column above hole (inches) (from hazard evaluation or best estimate)
LLF = Liquid Leak Factor incorporating discharge coefficient and liquid density (listed for each
toxic liquid in Exhibit B-2, Appendix B).
Remember that this equation only applies to liquids in tanks under atmospheric pressure. This
equation will give an overestimate of the release rate, because it does not take into account the
decrease in the release rate as the height of the liquid above the hole decreases. You may use
a computer model or another calculation method if you want a more realistic estimate of the
liquid release rate.
You may estimate the quantity that might be released by multiplying the liquid release rate from
the above equation by the time (in minutes) that likely would be needed to stop the release.
You should be able to substantiate the time needed to stop the release. Alternatively, you may
assume the release would stop when the level of liquid in the tank drops to the level of the hole.
You may estimate the quantity of liquid above that level in the tank from the dimensions of the
tank, the liquid level at the start of the leak, and the level of the hole. Assume the estimated
quantity is released into a pool and use the method and equations in Section 7.2.3 below to
determine the evaporation rate of the liquid from the pool and the duration of the release. As
discussed in Section 7.2.3, if you find that your estimated evaporation rate is greater than esti-
mated liquid release rate, you should use the liquid release rate as the release rate to air.

Annex 7
Example 21: Liquid Release from Atmospheric Tank (Allyl Alcohol)

You have a tank that contains 20,000 pounds of allyl alcohol at ambient temperature and
pressure. A valve on the side of the tank shears, leaving a hole in the tank wall 5 square inch-
es in area. The liquid column is 23 inches above the hole in the tank. From Exhibit B-2, the
Liquid Leak Factor for allyl alcohol is 41.
Therefore, from Equation 7-4, the liquid release rate is:
QRL = 5 x (23)1/2 x 41 = 983 pounds per minute
It takes 10 minutes to stop the release,
so 10 minutes x 983 pounds per minute = 9,830 pounds of allyl alcohol released.
Pressurized Tank
If you have a liquid stored in a tank under pressure, you may estimate a release rate for liquid
from a hole in the liquid space of the tank using the equation presented above for gases lique-
fied under pressure (Equation 7-2 in Section 7.1.1) or the equations in Appendix D, Section
D.7.1.
Release from Pipe
If you have a liquid flowing through a pipe at approximately atmospheric pressure, and the
pipeline remains at about the same height between the pipe inlet and the pipe break, you can
estimate the quantity of liquid released from the flow rate in the pipe and the time it would take
to stop the release by multiplying the flow rate by the time. For liquids at atmospheric pressure,
assume the liquid is spilled into a pool and use the methods in Section 7.2.3 below to estimate
the release rate to air.
For the release of a liquid under pressure from a long pipeline, you may use the equations below
(see Appendix D, Section D.7.2 for more information on these equations). These equations
apply both to substances that are liquid at ambient conditions and to gases liquefied under pres-
sure. This method does not consider the effects of friction in the pipe. First estimate the initial
operational flow velocity of the substance through the pipe using the initial operational flow rate
as follows:
Equation 7-5: Va = FR x DF x 0.033

Ap
where:
Va = Initial operational flow velocity (feet per minute)
FR = Initial operational flow rate (pounds per minute)
DF = Density Factor (from Exhibit B-2, Appendix B)
Ap = Cross-sectional area of pipe (square feet)
You can estimate the cross-sectional area of the pipe from the diameter or radius (half the diam-
eter of the pipe) using the formula for the area of a circle (area = r2, where r is the radius).
The release velocity is then calculated based on the initial operational flow, any gravitational
acceleration or deceleration effects resulting from changes in the height of the pipeline, and the
pressure difference between the pressure in the pipe and atmospheric pressure, using a form of
the Bernoulli equation:

Annex 7
Equation 7-6: Vb = 197 x [28.4 x(PT - 14.7) x DF] + [5.97 x (Za - Zb)] + [2.58 x 10-5 x Va2]
where:
Vb = Release velocity (feet per minute)
PT = Total pressure on liquid in pipe (psia)
DF = Density factor, see Exhibit B-1 or Exhibit B-2
Za = Height of pipeline at inlet (feet)
Zb = Height of pipeline at break (feet)
Va = Operational velocity (feet per minute), calculated from Equation 7-5.
Please note that if the height of the pipe at the release point is higher than the initial pipe height,
then Za - Zb is negative, and the height term will cause the estimated release velocity to decrease.
The release velocity can then be used to calculate a release rate as follows:
Equation 7-7: QRL = Vb x Ap
DF x 0.033
where:
QRL = Release rate (pounds per minute)
Vb = Release velocity (feet per minute)
DF = Density Factor
Ap = Cross-sectional area of pipe (square feet)
You may estimate the quantity released into a pool from the broken pipe by multiplying the liq-
uid release rate (QRL) from the equation above by the time (in minutes) that likely would be
needed to stop the release (or to empty the pipeline). Assume the estimated quantity is released
into a pool and use the method and equations described in Section 7.2.3 below to determine
the evaporation rate of the liquid from the pool. You must be able to substantiate the time
needed to stop the release.
As noted above in Section 7.1.1, for a release from a pipe of gas liquefied under pressure,
assume that the released liquid is immediately vaporized, and use the calculated liquid release
rate as the release rate to air. If the release duration would be very short (e.g., because of active
mitigation measures), determine the total quantity of the release as the release rate times the
duration, then estimate a new release rate as the quantity divided by 10. This will give you a
release rate that you can use with the 10-minute reference tables of distances in this guidance
to estimate a distance to the endpoint.
In the case of very long pipes, release rates from a shear or hole will be lower than the estimates
from this method because of pipe roughness and frictional head loss. If friction effects are
deemed considerable, an established method for calculating frictional head loss such as the
Darcy formula may be used.

Annex 7
7.2.2 Liquid Release Rate and Quantity Released for Mitigated

Releases
For alternative release scenarios, you are permitted to take credit for both passive and active mit-
igation systems, or a combination if both are in place. Active mitigation techniques that reduce
the rate of liquid release or the quantity released into the pool are discussed in this section.
Active and passive mitigation to reduce the evaporation rate of liquid from a pool are discussed
in the next section.
Active Mitigation to Reduce Quantity Released
Examples of mitigation techniques to reduce the quantity released into the pool include auto-
matic shutoff valves and emergency deinventory. You may use the equations in Section 7.2.1
above for calculating liquid release rate, if applicable. Estimate the approximate time needed to
stop the release by the mitigation technique (you must be able to justify your estimate). Multiply
the release rate times the duration of release to estimate quantity released. Assume the estimat-
ed quantity is released into a pool and use the method and equations described in Section 7.2.3
below to determine the evaporation rate of the liquid from the pool. You should also consider
mitigation (active or passive) of evaporation from the pool, if applicable, as discussed in Section
7.2.3 below.
Example 22: Mitigated Liquid Release
A bromine injection system suffers a hose failure; the greatly lowered system pressure triggers
an automatic shutoff valve within 30 seconds of the release. The flow rate out of the ruptured
hose is approximately 330 pounds per minute. Because the release occurred for only 30 sec-
onds (0.5 minutes), the total quantity spilled was 330 x 0.5, or 165 pounds.
7.2.3 Evaporation Rate from Liquid Pool
After you have estimated the quantity of liquid released, assume that the liquid forms a pool
and calculate the evaporation rate from the pool as described below. You may account for both
passive and active mitigation in estimating the release rate. Passive mitigation may include tech-
niques already discussed in Section 3.2.3 such as dikes and trenches. Active mitigation to reduce
the release rate of liquid in pools to the air may include an assortment of techniques including
foam or tarp coverings and water or chemical sprays. Some methods of accounting for passive
and active mitigation are discussed below.
If the calculated evaporation rate from the pool is greater than the liquid release rate you have
estimated from the container, no pool would be formed, and calculating the release rate as the
evaporation rate from a pool would not be appropriate. If the pool evaporation rate is greater
than the liquid release rate, use the liquid release rate as the release rate to air. Consider this
possibility particularly for relatively volatile liquids, gases liquefied by refrigeration, or liquids at
elevated temperature that form pools with no mitigation.
Unmitigated
Ambient temperature
For pools with no mitigation, if the liquid is always at ambient temperature, find the Liquid
Factor Ambient (LFA) and the Density Factor (DF) in Exhibit B-2 of Appendix B (see Appendix D,
Section D.2.2 for the derivation of these factors). If your ambient temperature is between 25°C
and 50°C, you may use this method to calculate the release rate, and then use the appropriate
Temperature Correction Factor from Exhibit B-4, Appendix B, to adjust the release rate, as
described below. For gases liquefied by refrigeration, use the Liquid Factor Boiling (LFB) and DF
from Exhibit B-1. Calculate the release rate from the following equation for liquids at ambient
temperature with no mitigation:

Annex 7
Equation 7-8: QR = QS x 2.4 x LFA x DF

where:
2.4 = Wind speed factor = 3.00.78, where 3.0 meters per second (6.7 miles per hour) is the
wind speed for the alternative scenario for purposes of this guidance
LFA = Liquid Factor Ambient
DF = Density Factor
This method assumes that the total quantity of liquid released spreads out to form a pool one
centimeter in depth; it does not take into account evaporation as the liquid is released.
Example 23: Evaporation from Pool Formed by Liquid Released from Hole in Tank (Allyl
Alcohol)
In Example 21, 9,830 pounds of allyl alcohol were estimated to be released from a hole in a
tank. From Exhibit B-2, the Density Factor for allyl alcohol is 0.58, and the Liquid Factor
Ambient is 0.0046. Assuming that the liquid is not released into a diked area or inside a build-
ing, the evaporation rate from the pool of allyl alcohol, from Equation 7-8, is:
For pools with no mitigation, if the liquid is at an elevated temperature (above 50°C or at or
close to its boiling point), find the Liquid Factor Boiling (LFB) and the Density Factor (DF) in Exhibit
B-2 of Appendix B (see Appendix D, Section D.2.2, for the derivation of these factors). For liq-
uids at temperatures between 25°C and 50°C, you may use the method above for ambient
temperature and apply the appropriate Temperature Correction Factor from Appendix B, Exhibit
B-4, to the result, as discussed below. For liquids above 50°C, or close to their boiling points, or
with no Temperature Correction Factors available, calculate the release rate of the liquid from
the following equation:
Equation 7-9: QR = QS x 2.4 x LFB x DF
where:
LFB = Liquid Factor Boiling
DF = Density Factor
Mitigated
Diked Areas
If the toxic liquid will be released into an area where it will be contained by dikes, compare the
diked area to the maximum area of the pool that could be formed, as described in Section 3.2.3
(see Equation 3-6). Also verify that the quantity spilled will be totally contained by the dikes. The
smaller of the two areas should be used in determination of the evaporation rate. If the maxi-
mum area of the pool is smaller than the diked area, calculate the release rate as described for
pools with no mitigation (above). If the diked area is smaller, and the spill will be totally con-
tained, go to Exhibit B-2 in Appendix B to find the Liquid Factor Ambient (LFA), if the liquid is at
ambient temperature, or the Liquid Factor Boiling (LFB), if the liquid is at an elevated tempera-
ture. For temperatures between 25°C and 50°C, you may use the appropriate Temperature
Correction Factor from Exhibit B-4, Appendix B, to adjust the release rate, as described below.

Annex 7
For gases liquefied by refrigeration, use the LFB. Calculate the release rate from the diked area
as follows for liquids at ambient temperature:
Equation 7-10: QR = 2.4 x LFA x A
or, for liquids at elevated temperatures or gases liquefied by refrigeration alone:
Equation 7-11: QR = 2.4 x LFA x B
where:
LFA = Liquid Factor Ambient (listed in Exhibit B-2, Appendix B)
LFB = Liquid Factor Boiling (listed in Exhibit B-1 or B-2, Appendix B)
A = Diked area (square feet)
Releases into Buildings

If a toxic liquid is released inside a building, compare the area of the building floor or any diked
area that would contain the spill to the maximum area of the pool that could be formed; the
smaller of the two areas should be used in determining the evaporation rate, as for the worst-
case scenario. The maximum area of the pool is determined from Equation 3-6 in Section 3.2.3
for releases into diked areas. The area of the building floor is the length times width of the floor
(in feet) (Equation 3-9).
If the floor area or diked area is smaller than the maximum pool size, estimate the outdoor evap-
oration rate from a pool the size of the floor area or diked area from Equation 7-10. If the max-
imum pool area is smaller, estimate the outdoor evaporation rate from a pool of maximum size
from Equation 7-8.
Estimate the rate of release of the toxic vapor from the building as five percent of the calculat-
ed outdoor evaporation rate (multiply your evaporation rate by 0.05). See Appendix D, Section
D.2.4 for more information on releases into buildings.
Active Mitigation to Reduce Evaporation Rate
Examples of active mitigation techniques to reduce the evaporation rate from the pool include
water sprays and foam or tarp covering. Use test data, manufacturer design specifications, or
past experience to determine the fractional reduction of the release rate by the mitigation tech-
nique. Apply this fraction to the release rate (evaporation rate from the pool) that would have
occurred without the mitigation technique, as follows:
Equation 7-12: QRRV = (1 - FR) x QR
where:
QRRV = Reduced evaporation rate (release rate to air) from pool (pounds per minute)
FR = Fractional reduction resulting from mitigation
QR = Evaporation rate from pool without mitigation (pounds per minute)
Temperature Corrections for Liquids at Temperatures
between 25°C and 50°C
If your liquid is at a temperature between 25°C (77°F) and 50°C (122°F), you may use the appro-
priate Temperature Correction Factor (TCF) from Exhibit B-4, Appendix B, to calculate a correct-
ed release rate. Calculate the release rate (QR) of the liquid at 25°C (77°F) as described above
for unmitigated releases or releases in diked areas and multiply the release rate by the appropri-
ate TCF as described in Section 3.2.5.

Annex 7
Evaporation Rate Compared to Liquid Release Rate

If you estimated the quantity of liquid in the pool based on an estimated liquid release rate from
a hole in a container or pipe, as discussed in Sections 7.2.1 and 7.2.2, compare the evaporation
rate with the liquid release rate.
If the evaporation rate from the pool is greater than the liquid release rate, use the liquid release
rate as the release rate to air.
Duration of Release
After you have estimated a release rate as described above, determine the duration of the vapor
release from the pool (the time it will take for the liquid pool to evaporate completely). To esti-
mate the time in minutes, divide the total quantity released (in pounds) by the release rate (in
pounds per minute) (see Equation 3-5 in Section 3.2.2). If you are using the liquid release rate
as the release rate to air, as discussed in the preceding paragraph, estimate a liquid release dura-
tion as discussed in Section 7.2.1 or 7.2.2. The duration could be the time it would take to stop
the release or the time it would take to empty the tank or to release all the liquid above the level
of the leak. If you have corrected the release rate for a temperature above 25°C, use the cor-
rected release rate to estimate the duration.
7.2.4 Common Water Solutions and Oleum
You may use the methods described above in Sections 7.2.1, 7.2.2, and 7.2.3 for pure liquids
to estimate the quantity of a solution of a toxic substance or oleum that may be spilled into a
pool. LFA, DF, and LLF values for several concentrations of ammonia, formaldehyde, hydrochlo-
ric acid, hydrofluoric acid, and nitric acid in water solution and for oleum are listed in Appendix
B, Exhibit B-3. The LFA for a wind speed of 3.0 meters per second (6.7 miles per hour) should
be used in the release rate calculations for alternative scenarios for pools of solutions at ambi-
ent temperature.
For unmitigated releases or releases with passive mitigation, follow the instructions in Section
7.2.3. If active mitigation measures are in place, you may estimate a reduced release rate from
the instructions on active mitigation in Section 7.2.2. Use the total quantity of the solution as
the quantity released from the vessel or pipeline (QS) in carrying out the calculation of the
release rate to the atmosphere.
If the solution is at an elevated temperature, see Section 3.3. As discussed in Section 3.3, you
may treat the release of the substance in solution as a release of the pure substance.
Alternatively, if you have vapor pressure data for the solution at the release temperature, you
may estimate the release rate from the equations in Appendix D, Sections D.2.1 and D.2.2.
If you estimated the quantity of solution in the pool based on an estimated liquid release rate
from a hole in a container or pipe, as discussed in Sections 7.2.1 and 7.2.2, compare the evap-
oration rate with the liquid release rate. If the evaporation rate from the pool is greater than the
liquid release rate, use the liquid release rate as the release rate to air.

Annex 7
8. Estimation of Distance to the Endpoint for

Alternative Scenarios for Toxic Substances
For estimating consequence distances for alternative scenarios for toxic substances, this guid-
ance provides four generic reference tables for neutrally buoyant gases and vapors and four for
dense gases. The generic reference tables of distances (Reference Tables 14-21) are found at the
end of Chapter 10. The generic tables and the conditions for which each table is applicable are
described in Exhibit 4. Four chemical-specific tables also are provided for ammonia, chlorine, and
sulfur dioxide. The chemical-specific reference tables follow the generic reference tables at the
end of Chapter 10. These tables, and the applicable conditions, are described in Exhibit 5.
All the reference tables of distances for alternative scenarios were developed assuming D stabil-
ity and a wind speed of 3.0 meters per second (6.7 miles per hour) as representative of likely
conditions for many sites. Many wind speed and atmospheric stability combinations may be
possible at different times in different parts of the country. If D stability and 3.0 meters per sec-
ond are not reasonable conditions for your site, you may want to use other methods to esti-
mate distances.
For simplicity, this guidance assumes ground level releases. This guidance, therefore, may over-
estimate the consequence distance if your alternative scenario involves a release above ground
level, particularly for neutrally buoyant gases and vapors. If you want to assume an elevated
release, you may want to consider other methods to determine the consequence distance.
The generic reference tables should be used for all toxic substances other than ammonia, chlo-
rine, and sulfur dioxide. To use the generic reference tables, you need to consider the release
rates estimated for gases and evaporation from liquid pools and the duration of the release. For
the alternative scenarios, the duration of toxic gas releases may be longer than the 10 minutes
assumed for the worst-case analysis for gases. You need to determine the appropriate toxic end-
point and whether the gas or vapor is neutrally buoyant or dense, using the tables in Appendix
B and considering the conditions of the release. You may interpolate between entries in the ref-
erence tables.
Note the following concerning the use of the chemical-specific reference tables for ammonia,
chlorine, and sulfur dioxide:
• The table for anhydrous ammonia (Reference Table 22) applies only to flashing releases of
ammonia liquefied under pressure. Use Table 23 for release of ammonia as a gas
(e.g., evaporation from a pool or release from the vapor space of a tank).
• You may use these tables for releases of any duration.
To use the reference tables of distances, follow these steps:
For Regulated Toxic Substances Other than Ammonia, Chlorine, and Sulfur Dioxide
• Find the toxic endpoint for the substance in Appendix B (Exhibit B-1 for toxic gases or
Exhibit B-2 for toxic liquids).
• Determine whether the table for neutrally buoyant or dense gases and vapors is appropriate
from Appendix B (Exhibit B-1 for toxic gases or Exhibit B-2, column for alternative case, for
toxic liquids). A toxic gas that is lighter than air may behave as a dense gas upon release if it
is liquefied under pressure, because the released gas may be mixed with liquid droplets, or if
it is cold. Consider the state of the released gas when you decide which table is appropriate.
∆ Use the urban table if your site is in an urban or obstructed area.

Annex 7
Exhibit 4
Generic Reference Tables of Distances for Alternative Scenarios
Reference Release Topography Gas

Table Duration or Vapor
Number (minutes) Density

18 10 Rural Dense
19 60 Rural Dense
20 10 Urban Dense
21 60 Urban Dense
Exhibit 5
Chemical-specific Reference Tables of Distances for

Alternative Scenarios
Gas Release Reference
Substance or Vapor Duration Topography Table
Anhydrous ammonia Dense 10-60 Rural 22

liquefied under Urban
pressure
Non-liquefied Neutrally buoyant 10-60 Rural 23
ammonia, Urban
ammonia liquefied
by refrigeration
or aqueous ammonia
Chlorine Dense 10-60 Rural 24
Urban
Sulfur dioxide Dense 10-60 Rural 25
(anhydrous) Urban

Annex 7
• Determine whether the 10-minute table or the 60-minute table is appropriate.

∆ Use the 10-minute table for releases from evaporating pools of common water
solutions and of oleum.
∆ If you estimated the release duration for gas release or pool evaporation to be 10
minutes or less, use the 10-minute table.
∆ If you estimated the release duration for gas release or pool evaporation to be more
than 10 minutes, use the 60-minute table.
• If Exhibit B-1 or B-2 indicates the gas or vapor should be considered neutrally buoyant, and
other factors would not cause the gas or vapor to behave as a dense gas, divide the esti-
mated release rate (pounds per minute) by the toxic endpoint (milligrams per liter).
• Find the range of release rate/toxic endpoint values that includes your calculated release
rate/toxic endpoint in the first column of the appropriate table (Reference Table 14, 15, 16,
or 17), then find the corresponding distance to the right.
• If Exhibit B-1 or B-2 or consideration of other relevant factors indicates the substance should
be considered a dense gas or vapor (heavier than air), find the distance in the appropriate
table (Reference Table 18, 19, 20, or 21) as follows:
∆ Find the toxic endpoint closest to that of the substance by reading across the top of the
table. If the endpoint of the substance is halfway between two values on the table,
choose the value on the table that is smaller (to the left). Otherwise, choose the closest
value to the right or the left.
∆ Read across from the release rate and down from the endpoint to find the distance
corresponding to the toxic endpoint and release rate for your substance.
For Ammonia, Chlorine, or Sulfur Dioxide
• Find the appropriate chemical-specific table for your substance (see the descriptions of
Reference Tables 22-25 in Exhibit 5).
∆ If you have ammonia liquefied by refrigeration alone, you may use Reference Table 23,
even if the duration of the release is greater than 10 minutes.
∆ If you have chlorine or sulfur dioxide liquefied by refrigeration alone, you may use the
chemical-specific reference tables, even if the duration of the release is greater than 10
minutes.
• Determine whether rural or urban topography is applicable to your site.
∆ Use the rural column in the reference table if your site is in an open area with few
obstructions.
∆ Use the urban column if your site is in an urban or obstructed area.
• Estimate the consequence distance as follows:
∆ In the left-hand column of the table, find the release rate closest to your calculated
release rate.
∆ Read the corresponding distance from the appropriate column (urban or rural) to the
right.

Annex 7
The development of the generic reference tables is discussed in Appendix D, Sections D.4.1 and
D.4.2. The development of the chemical-specific reference tables is discussed in industry-specif-
ic risk management program guidance documents and a backup information document that
are cited in Section D.4.3. If you think the results of the method presented here overstate the
potential consequences of your alternative release scenario, you may choose to use other meth-
ods or models that take additional site-specific factors into account.
Examples 24 and 25 below include the results of modeling using two other models, ALOHA and
WHAZAN, for comparison with the results of the methods presented in this guidance. Appendix
D, Section D.4.5 provides additional information on this modeling.
Example 24: Gas Release of Chlorine

Assume that you calculated a release rate of 500 pounds per minute of chlorine from a tank.
A chemical-specific table is provided for chlorine, so you do not need to consult Appendix B
for information on chlorine. The topography of your site is urban. For a release of chlorine
under average meteorology (D stability and 3 meters per second wind speed), go to Reference
Table 24. The estimated release rate of 500 pounds per minute, with urban topography, cor-
responds to a consequence distance of 0.4 miles.
• The ALOHA model gave a distance of 3.0 miles to the endpoint,
using the same assumptions.
• The WHAZAN model gave a distance of 3.2 miles to the endpoint,
using the same assumptions and the dense cloud dispersion model.
Example 25: Allyl Alcohol Evaporating from Pool

In Example 23, the evaporation rate of allyl alcohol from a pool was calculated as 63 pounds
per minute. The total quantity in the pool was estimated as 9,830 pounds; therefore, the pool
would evaporate in 9,830/63 or 156 minutes. You would use a 60-minute reference table to
estimate the distance to the endpoint. From Exhibit B-2 in Appendix B, the toxic endpoint for
allyl alcohol is 0.036 mg/L, and the appropriate reference table for the alternative scenario
analysis is a neutrally buoyant plume table. To find the distance from the neutrally buoyant
plume tables, you need the release rate divided by the endpoint. In this case, it is 63/0.036, or
1,750. Assuming the release takes place in a rural location, you use Reference Table 15, appli-
cable to neutrally buoyant plumes, 60-minute releases, and rural conditions. From this table,
you estimate the distance as 0.4 mile.
• The ALOHA model gave a distance of 0.7 mile to the endpoint for a release rate of 63
pounds per minute, using the same assumptions and the dense gas model.
• The WHAZAN model gave a distance of 0.5 mile to the endpoint for a release rate of 63
pounds per minute, using the same assumptions and the buoyant plume dispersion model.

Annex 7
9. Estimation of Release Rates for Alternative

Scenarios for Flammable Substances
9.1 Flammable Gases

Gaseous Release from Tank or Pipe
An alternative scenario for a release of a flammable gas may involve a leak from a vessel or pip-
ing. To estimate a release rate for flammable gases from hole size and storage conditions, you
may use the method described above in Section 7.1.1 for toxic gases. This release rate may be
used to determine the dispersion distance to the lower flammability limit (LFL), as described in
Section 10.1. Exhibit C-2 in Appendix C includes Gas Factors (GF) that may be used in carrying
out the calculations for each of the regulated flammable gases.
Example 26: Release Rate of Flammable Gas from Hole in Tank (Ethylene)
A pipe tears off a tank containing ethylene. The pipe is in the vapor space of the tank. The
release rate from the hole can be estimated from Equation 7-1 in Section 7.1. You estimate
that the pipe would leave a hole with an area (HA) of 5 square inches. The temperature inside
the tank (Tt , absolute temperature, Kelvin) is 282 K, 9°C, and the square root of the tempera-
ture is 16.8. The pressure in the tank (Pt) is approximately 728 pounds per square inch
absolute (psia). From Exhibit C-2, Appendix C, the gas factor (GF) for ethylene is 18. From
Equation 7-1, the release rate (QR) is:
QR = 5 x 728 x (1/16.8) x 18 = 3,900 pounds per minute
Gases Liquefied Under Pressure

A vapor cloud fire is a possible result of a release of a gas liquefied under pressure. You may use
the methods described in Section 7.1.1 for toxic gases liquefied under pressure to estimate the
release rate from a hole in a tank for a flammable gas liquefied under pressure. The estimated
release rate may be used to estimate the dispersion distance to the LFL for a vapor cloud fire.
Flammable gases that are liquefied under pressure may be released very rapidly, with partial
vaporization of the liquefied gas and possible aerosol formation. Section 10.4 presents a
method for estimating the consequences of a vapor cloud explosion from such a release of a
gas liquefied under pressure.
Gases Liquefied by Refrigeration
Flammable gases liquefied by refrigeration alone can be treated as liquids for the alternative sce-
nario analysis, as discussed in Section 9.2 and Section 10.2, below.
9.2 Flammable Liquids

You may estimate a release rate for flammable liquids by estimating the evaporation rate from
a pool. Release rates also can be estimated for flammable gases liquefied by refrigeration alone
by this method, if the liquefied gas is likely to form a pool upon release. You first need to esti-
mate the quantity in the pool.
You may use the method discussed in Section 7.2.1 to estimate a rate of liquid release for flam-
mable liquids into a pool from a hole in a tank or from a pipe shear. Exhibit C-3 in Appendix C
includes liquid leak factors (LLF) for calculating release rate from a hole. Note that the LLF is
appropriate only for atmospheric tanks. LLF values are not provided for liquefied flammable
gases; you will need to estimate the quantity in the pool from other information for liquefied
flammable gases.

Annex 7
Once you have an estimate of the quantity of flammable liquid in a pool, you may use the meth-
ods presented in Section 7.2.3 to estimate the evaporation rate from the pool. Liquid factors at
ambient and boiling temperature (LFA and LFB) for liquids for the calculation are listed in Exhibit
C-3 in Appendix C, and LFBs for liquefied gases are listed in Exhibit C-2. Both passive and active
mitigation measures (discussed in Sections 7.2.2 and 7.2.3) may be taken into account. You do
not need to estimate the duration of the release, because this information is not used to esti-
mate distance to the LFL, as discussed in the next chapter.
As for toxic liquids, if the rate of evaporation of the liquid from the pool is greater than the rate
of release of the liquid from the container, you should use the liquid release rate, not the pool
evaporation rate, as the rate of release to the air. You should expect rapid evaporation rates for
liquefied flammable gases from a pool. All of the regulated flammable liquids are volatile, so the
evaporation rate from a pool may be expected to be relatively high, particularly without mitiga-
tion.

Annex 7
10. Estimation of Distance to the Endpoint for

Alternative Scenarios for Flammable Substances
10.1 Vapor Cloud Fires

The distance to the LFL represents the maximum distance at which the radiant heat effects of a
vapor cloud fire might have serious consequences. Exhibit C-2, Appendix C, provides LCL data
(in volume percent and milligrams per liter) for listed flammable gases; Exhibit C-3 provides these
data for flammable liquids. This guidance provides reference tables for the alternative scenario
conditions assumed in this guidance (D stability and wind speed 3.0 meters per second, ground
level releases) for estimating the distance to the LCL. Release rate is the primary factor for deter-
mining distance to the flammable endpoint. Because the methods used in this guidance assume
that the vapor cloud release is in a steady state and that vapor cloud fires are nearly instanta-
neous events, release duration is not a critical factor for estimating vapor cloud fire distances.
Thus, the reference tables for flammable substances are not broken out separately by release
duration (e.g., 10 minutes, 60 minutes). The development of these tables is discussed further in
Appendix D, Section D.4. The reference tables for flammable substances (Reference Tables 26-
29 at the end of Chapter 10) are listed in Exhibit 6.
To use the reference tables of distances to find the distance to the LFL from the release rate, fol-
low these steps:
• Find the LFL endpoint for the substance in Appendix C (Exhibit C-2 for flammable gases or
Exhibit C-3 for flammable liquids).
• Determine from Appendix C whether the table for neutrally buoyant or dense gases and
vapors is appropriate (Exhibit C-2 for flammable gases or Exhibit C-3 for flammable liquids). A
gas that is lighter than air may behave as a dense gas upon release if it is liquefied under pres-
sure, because the released gas may be mixed with liquid droplets, or if it is cold. Consider the
state of the released gas when you decide which table is appropriate.
∆ Use the urban table if your site is in an urban or obstructed area.
Exhibit 6
Reference Tables of Distances for Vapor Cloud Fires of

Flammable Substances
Gas or Release Reference

Vapor Topography Duration Table
Neutrally buoyant Rural 10-60 26
Neutrally buoyant Urban 10-60 27
Dense Rural 10-60 28
, Dense Urban 10-60 29

Annex 7

• If Exhibit C-2 or C-3 indicates the gas or vapor should be considered neutrally buoyant, and
other factors would not cause the gas or vapor to behave as a dense gas, divide the estimat-
ed release rate (pounds per minute) by the LFL endpoint (milligrams per liter).
• Find the range of release rate/LFL values that includes your calculated release rate/LFL in the
first column of the appropriate table (Reference Table 26 or 27), then find the corresponding
distance to the right.
• If Exhibit C-2 or C-3 or consideration of other relevant factors indicates the substance should
be considered a dense gas or vapor (heavier than air), find the distance in the appropriate table
(Reference Table 28 or 29) as follows:
∆ Find the LFL closest to that of the substance by reading across the top of the table. If
the LFL of the substance is halfway between two values on the table, choose the value
on the table that is smaller (to the left). Otherwise, choose the closest value to the right
or the left.
∆ Read across from the release rate and down from the LFL to find the distance corre-
sponding to the LFL and release rate for your substance.
Example 27: Flammable Gas Release (Ethylene)

In Example 26, you estimated a release rate for ethylene from a hole in a tank of 3,900
pounds per minute. You want to estimate the distance to the LFL for a vapor cloud fire result-
ing from this release.
From Exhibit C-2, Appendix C, the LFL for ethylene is 31 mg/L, and the appropriate table for
distance estimation is a neutrally buoyant gas table for flammable substances. Your site is in a
rural area, so you would use Reference Table 26.
To use the neutrally buoyant gas tables, you need to calculate release rate/endpoint. In this
case, release rate/LFL = 3,900/31 or 126. On Reference Table 26, 126 falls in the range of
release rate/LFL values corresponding to 0.2 miles.
Example 28: Vapor Cloud Fire from Evaporating Pool of Flammable Liquid
You have a tank containing 20,000 pounds of ethyl ether. A likely scenario for a release might
be shearing of a pipe from the tank, with the released liquid forming a pool. You want to
estimate the consequences of a vapor cloud fire that might result from evaporation of the
pool and ignition of the vapor.
You first need to estimate the rate of release of the liquid from the tank. You can do this using
Equation 7-4, Section 7.2.1. For this calculation, you need the area of the hole that would result
from shearing the pipe (HA), the height of the liquid in the tank above the hole (LH), and the
liquid leak factor (LLF) for ethyl ether, from Exhibit C-3 in Appendix C. The pipe diameter is 2
inches, so the cross sectional area of the hole would be 3.1 square inches. You estimate that the
pipe is 2 feet, or 24 inches, below the level of the liquid when the tank is full. The square root
of LH (24 inches) is 4.9. LLF for ethyl ether is 34. From Equation 7-4, the rate of release of the
liquid from the hole is calculated as:

Annex 7
QRL = 3.1 x 4.9 x 34

You estimate that the release of the liquid could be stopped in about 10 minutes. In 10 min-
utes, 10 x 520, or 5,200 pounds, would be released.
The liquid would be released into an area without dikes. To estimate the evaporation rate from
the pool formed by the released liquid, you use Equation 7-8 from Section 7.2.3. To carry out
the calculation, you need the Liquid Factor Ambient (LFA) and the Density Factor (DF) for ethyl
ether. From Exhibit C-3, Appendix C, LFA for ethyl ether is 0.11 and DF is 0.69. The release rate
to air is:
QR = 5,200 x 2.4 x 0.11 x 0.69
The evaporation rate from the pool is greater than the estimated liquid release rate; therefore,
you use the liquid release rate of 520 pounds per minute as the release rate to air. To estimate
the maximum distance at which people in the area of the vapor cloud could suffer serious injury,
estimate the distance to the lower flammability limit (LFL) (in milligrams per liter) for ethyl ether,
from the appropriate reference table. From Exhibit C-3, Appendix C, LFL for ethyl ether is 57
mg/L, and the appropriate reference table is a dense gas table. Your site is in a rural area with
few obstructions, so you use Reference Table 28.
From Reference Table 28, the closest LFL is 60 mg/L. The lowest release rate on the table is 1,500
pounds per minute, which is higher than the evaporation rate estimated for the pool of ethyl
ether. For a release rate less than 1,500 pounds per minute, the distance to the LFL is less than
0.1 miles.
10.2 Pool Fires

Pool fires may be considered as potential alternative scenarios for flammable liquids, including
gases liquefied by refrigeration alone. You may find, however, that other scenarios will give a
greater distance to the endpoint and, therefore, may be more appropriate as alternative scenar-
ios. A “Pool Fire Factor” (PFF) has been derived for each of the regulated flammable liquids and
most of the flammable gases to aid in the consequence analysis. The derivation of these factors
is discussed in Appendix D, Section D.9. The PFF, listed in Appendix C, Exhibit C-2 for flamma-
ble gases and C-3 for flammable liquids, may be used to estimate a distance from the center of
a pool fire where people could potentially receive second degree burns from a 40-second expo-
sure. The heat radiation endpoint for this analysis is 5 kilowatts per square meter (kW/m2).
Ambient temperature is assumed to be 25°C (77°F) for calculation of the PFF for flammable liq-
uids.

Annex 7
To estimate a distance using the PFF, you first need to estimate the size of the pool, in square
feet, that might be formed by the release of a flammable substance. You may use the methods
described above for toxic liquids to estimate pool size. Density factors (DF) for the estimation of
pool size in undiked areas may be found for flammable gases and flammable liquids in Exhibits
C-2 and C-3 of Appendix C. For flammable gases, the DF is based on the density at the boiling
point. You may want to consider whether the released substance may evaporate too quickly to
form a pool of the maximum size, particularly for liquefied gases.
Distances may be estimated from the PFF and the pool area as follows:
Equation 10-1: d = PFF x A
where:
d = Distance (feet)
PFF = Pool Fire Factor (listed for each flammable substance in Appendix C,
Exhibits C-2 and C-3)
A = Pool area (square feet)
Example 29: Pool Fire of Flammable Liquid

For a tank containing 20,000 pounds of ethyl ether, you want to estimate the consequences
of a pool fire. You estimate that 15,000 pounds would be released into an area without dikes,
forming a pool. Assuming the liquid spreads to a depth of 1 centimeter (0.39 inches), you
estimate the area of the pool formed from Equation 3-6, Section 3.2.3. For this calculation,
you need the density factor (DF) for ethyl ether; from Exhibit C-3, Appendix C, DF for ethyl
ether is 0.69. From Equation 3-6, the area of the pool is:
A = 15,000 x 0.69 = 10,400 square feet
You can use Equation 10-1 to estimate the distance from the center of the burning pool
where the heat radiation level would reach 5 kW/m2. For the calculation, you need the square
root of the pool area (A) and the pool fire factor (PFF) for ethyl ether. The square root of A,
10,400 square feet, is 102 feet. From Exhibit C-3, Appendix C, PFF for ethyl ether is 4.3. From
Equation 10-1, the distance (d) to 5 kW/m2 is:
d = 4.3 x 102 = 440 feet (about 0.08 miles)
If you have a gas that is liquefied under pressure or under a combination of pressure and refrig-
eration, a pool fire is probably not an appropriate alternative scenario. A fire or explosion involv-
ing the flammable gas that is released to the air by a sudden release of pressure is likely to have
the potential for serious effects at a greater distance than a pool fire (e.g., see the methods for
analysis of BLEVEs and vapor cloud explosions in Sections 10.3 and 10.4 below, or see Appendix
A for references that provide more information on consequence analysis for fires and explo-
sions).

Annex 7
10.3 BLEVEs
If a fireball from a BLEVE is a potential release scenario at your site, you may use Reference Table
30 to estimate the distance to a potentially harmful radiant heat level. The table shows distances
for a range of quantities to the radiant heat level that potentially could cause second degree
burns to a person exposed for the duration of the fire. The quantity you use should be the total
quantity in a tank that might be involved in a BLEVE. The equations used to derive this table of
distances are presented in Appendix D, Section D.10. If you prefer, you may use the equations
to estimate a distance for BLEVEs, or you may use a different calculation method or model.
10.4 Vapor Cloud Explosion

If you have the potential at your site for the rapid release of a large quantity of a flammable
vapor, particularly into a congested area, a vapor cloud explosion may be an appropriate alter-
native release scenario.
For the consequence analysis, you may use the same methods as for the worst case to estimate
consequence distances to an overpressure endpoint of 1 psi (see Section 5.1 and the equation
in Appendix C). Instead of assuming the total quantity of flammable substance released is in the
vapor cloud, you may estimate a smaller quantity in the cloud. You could base your estimate of
the quantity in the cloud on the release rate estimated as described above for gases and liquids
multiplied by the time required to stop the release.
To estimate the quantity in the cloud for a gas liquefied under pressure (not refrigerated), you
may use the equation below. This equation incorporates a “flash fraction factor” (FFF), listed in
Appendix C, Exhibit C-2 for regulated flammable gases, to estimate the quantity that could be
immediately flashed into vapor upon release. A factor of two is included to estimate the quan-
tity that might be carried along as spray or aerosol. See Appendix D, Section D.11 for the deri-
vation of this equation. The equation is:
Equation 10-2: QF = FFF x QS x 2

where:
QF = Quantity flashed into vapor plus aerosol (pounds) (cannot be larger than QS)
FFF = Flash fraction factor (unitless) (listed in Appendix C, Exhibit C-2) (must be less than 1)
QS = Quantity spilled (pounds)
2 = Factor to account for spray and aerosol
For derivation of the FFF, the temperature of the stored gas was assumed to be 25°C (77°F)
(except as noted in Exhibit C-2). You may estimate the flash fraction under other conditions
using the equation presented in Appendix D, Section D.11.
You may estimate the distance to 1 psi for a vapor cloud explosion from the quantity in the cloud
using Reference Table 13 (at the end of the worst-case analysis discussion) or from Equation C-
1 in Appendix C. For the alternative scenario analysis, you may use a yield factor of 3 percent,
instead of the yield factor of 10 percent used in the worst-case analysis. As discussed in
Appendix D, Section D.11, the yield factor of 3 percent is representative of more likely events,
based on data from past vapor cloud explosions. If you use the equation in Appendix C, use
0.03 instead of 0.1 in the calculation. If you use Reference Table 13, you can incorporate the
lower yield factor by multiplying the distance you read from Reference Table 13 by 0.67.

Annex 7
Example 30: Vapor Cloud Explosion (Propane)

You have a tank containing 50,000 pounds of propane liquefied under pressure at ambient tem-
perature. You want to estimate the consequence distance for a vapor cloud explosion resulting
from rupture of the tank.
You use Equation 10-2 to estimate the quantity that might be released to form a cloud. You
base the calculation on the entire contents of the tank (QS = 50,000 pounds). From Exhibit C-
2 of Appendix C, the Flash Fraction Factor (FFF) for propane is 0.38. From Equation 10-2, the
quantity flashed into vapor, plus the quantity that might be carried along as aerosol (QF) is:
QF = 0.38 x 50,000 x 2 = 38,000 pounds
You assume 38,000 pounds of propane is in the flammable part of the vapor cloud. This quan-
tity falls between 20,000 pounds and 50,000 pounds in Reference Table 13; 50,000 pounds is
the quantity closest to your quantity. From the table, the distance to 1 psi overpressure is 0.3
mile for 50,000 pounds of propane for a 10 percent yield factor. To change the yield factor to
3 percent, you multiply this distance by 0.67; then the distance becomes 0.2 mile.

Annex 7
REFERENCE TABLE 14

D Stability, Wind Speed 3.0 Meters per Second
0 - 64 0.1 130,000 - 140,000 4.8

64 - 510 0.2 140,000 - 160,000 5.0
510 - 1,300 0.3 160,000 - 180,000 5.2
1,300 - 2,300 0.4 180,000 - 190,000 5.4
2,300 - 4,100 0.6 190,000 - 210,000 5.6
4,100 - 6,300 0.8 210,000 - 220,000 5.8
6,300 - 8,800 1.0 220,000 - 240,000 6.0
8,800 - 12,000 1.2 240,000 - 261,000 6.2
12,000 - 16,000 1.4 261,000 - 325,000 6.8
16,000 - 19,000 1.6 325,000 - 397,000 7.5
19,000 - 22,000 1.8 397,000 - 477,000 8.1
22,000 - 26,000 2.0 477,000 - 566,000 8.7
26,000 - 30,000 2.2 566,000 - 663,000 9.3
30,000 - 36,000 2.4 663,000 - 769,000 9.9
36,000 - 42,000 2.6 769,000 - 1,010,000 11
42,000 - 47,000 2.8 1,010,000 - 1,280,000 12
47,000 - 54,000 3.0 1,280,000 - 1,600,000 14
54,000 - 60,000 3.2 1,600,000 - 1,950,000 15
60,000 - 70,000 3.4 1,950,000 - 2,340,000 16
70,000 - 78,000 3.6 2,340,000 - 2,770,000 17
78,000 - 87,000 3.8 2,770,000 - 3,240,000 19
87,000 - 97,000 4.0 3,240,000 - 4,590,000 22
97,000 - 110,000 4.2 4,590,000 - 6,190,000 25
110,000 - 120,000 4.4 >6,190,000 >25*
120,000 - 130,000 4.6

Annex 7
REFERENCE TABLE 15

0 - 79 0.1 100,000 - 108,000 4.8

79 - 630 0.2 108,000 - 113,000 5.0
630 - 1,600 0.3 120,000 - 126,000 5.4
1,600 - 2,800 0.4 126,000 - 132,000 5.6
2,800 - 5,200 0.6 132,000 - 140,000 5.8
5,200 - 7,900 0.8 140,000 - 150,000 6.0
7,900 - 11,000 1.0 150,000 - 151,000 6.2
11,000 - 14,000 1.2 151,000 - 171,000 6.8
14,000 - 19,000 1.4 171,000 - 191,000 7.5
19,000 - 23,000 1.6 191,000 - 212,000 8.1
23,000 - 27,000 1.8 212,000 - 233,000 8.7
27,000 - 32,000 2.0 233,000 - 256,000 9.3
32,000 - 36,000 2.2 256,000 - 280,000 9.9
36,000 - 42,000 2.4 280,000 - 332,000 11
42,000 - 47,000 2.6 332,000 - 390,000 12
47,000 - 52,000 2.8 390,000 - 456,000 14
52,000 - 57,000 3.0 456,000 - 529,000 15
57,000 - 61,000 3.2 529,000 - 610,000 16
61,000 - 68,000 3.4 610,000 - 699,000 17
68,000 - 73,000 3.6 699,000 - 796,000 19
73,000 - 79,000 3.8 796,000 - 1,080,000 22
79,000 - 84,000 4.0 1,080,000 - 1,410,000 25
84,000 - 91,000 4.2 >1,410,000 >25*
91,000 - 97,000 4.4
97,000 - 100,000 4.6

Annex 7
REFERENCE TABLE 16

0 - 160 0.1 600,000 - 660,000 4.8

160 - 1,400 0.2 660,000 - 720,000 5.0
1,400 - 3,600 0.3 720,000 - 810,000 5.2
3,600 - 6,900 0.4 810,000 - 880,000 5.4
6,900 - 13,000 0.6 880,000 - 950,000 5.6
13,000 - 22,000 0.8 950,000 - 1,000,000 5.8
22,000 - 31,000 1.0 1,000,000 - 1,100,000 6.0
31,000 - 42,000 1.2 1,100,000 - 1,220,000 6.2
42,000 - 59,000 1.4 1,220,000 - 1,530,000 6.8
59,000 - 73,000 1.6 1,530,000 - 1,880,000 7.5
73,000 - 88,000 1.8 1,880,000 - 2,280,000 8.1
88,000 - 100,000 2.0 2,280,000 - 2,710,000 8.7
100,000 - 120,000 2.2 2,710,000 - 3,200,000 9.3
120,000 - 150,000 2.4 3,200,000 - 3,730,000 9.9
150,000 - 170,000 2.6 3,730,000 - 4,920,000 11
170,000 - 200,000 2.8 4,920,000 - 6,310,000 12
200,000 - 230,000 3.0 6,310,000 - 7,890,000 14
230,000 - 260,000 3.2 7,890,000 - 9,660,000 15
260,000 - 310,000 3.4 9,660,000 - 11,600,000 16
310,000 - 340,000 3.6 11,600,000 - 13,800,000 17
340,000 - 390,000 3.8 13,800,000 - 16,200,000 19
390,000 - 430,000 4.0 16,200,000 - 23,100,000 22
430,000 - 490,000 4.2 23,100,000 - 31,300,000 25
490,000 - 540,000 4.4 >31,300,000 >25*
540,000 - 600,000 4.6

Annex 7
REFERENCE TABLE 17

0 - 200 0.1 460,000 - 490,000 4.8

200 - 1,700 0.2 490,000 - 520,000 5.0
1,700 - 4,500 0.3 520,000 - 550,000 5.2
4,500 - 8,600 0.4 550,000 - 580,000 5.4
8,600 - 17,000 0.6 580,000 - 610,000 5.6
17,000 - 27,000 0.8 610,000 - 640,000 5.8
27,000 - 39,000 1.0 640,000 - 680,000 6.0
39,000 - 53,000 1.2 680,000 - 705,000 6.2
53,000 - 73,000 1.4 705,000 - 804,000 6.8
73,000 - 90,000 1.6 804,000 - 905,000 7.5
90,000 - 110,000 1.8 905,000 - 1,010,000 8.1
110,000 - 130,000 2.0 1,010,000 - 1,120,000 8.7
130,000 - 150,000 2.2 1,120,000 - 1,230,000 9.3
150,000 - 170,000 2.4 1,230,000 - 1,350,000 9.9
170,000 - 200,000 2.6 1,350,000 - 1,620,000 11
200,000 - 220,000 2.8 1,620,000 - 1,920,000 12
220,000 - 240,000 3.0 1,920,000 - 2,250,000 14
240,000 - 270,000 3.2 2,250,000 - 2,620,000 15
270,000 - 300,000 3.4 2,620,000 - 3,030,000 16
300,000 - 320,000 3.6 3,030,000 - 3,490,000 17
320,000 - 350,000 3.8 3,490,000 - 3,980,000 19
350,000 - 370,000 4.0 3,980,000 - 5,410,000 22
370,000 - 410,000 4.2 5,410,000 - 7,120,000 25
410,000 - 430,000 4.4 >7,120,000 >25*
430,000 - 460,000 4.6 *Report distance as 25 miles

REFERENCE TABLE 18
Toxic Endpoint (mg/L)
Release
Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 0.6 0.4 0.4 0.2 0.2 0.1 0.1 0.1 <01 <0.1 # # # # # #
2 0.9 0.6 0.5 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 <0.1 # # # #
5 1.4 1.1 0.9 0.6 0.4 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 # # #
10 2.0 1.5 1.2 0.9 0.6 0.5 0.4 0.4 0.2 0.2 0.1 0.1 0.1 <0.1 <0.1 #
30 3.7 2.7 2.2 1.5 1.1 0.9 0.7 0.7 0.5 0.3 0.3 0.2 0.2 0.1 0.1 <0.1
50 5.0 3.7 3.0 2.1 1.9 1.2 1.0 0.9 0.6 0.4 0.4 0.3 0.2 0.2 0.1 0.1
100 7.4 5.3 4.3 3.0 2.3 1.7 1.4 1.2 0.9 0.6 0.6 0.4 0.4 0.2 0.2 0.1
150 8.7 6.8 5.5 3.8 2.8 2.3 1.9 1.6 1.1 0.8 0.7 0.6 0.5 0.3 0.2 0.2
250 12 8.7 7.4 5.0 3.7 3.0 2.4 2.1 1.4 1.1 0.9 0.7 0.5 0.4 0.3 0.2
500 17 13 11 7.4 5.3 4.5 3.6 3.0 2.1 1.6 1.3 1.1 0.9 0.6 0.4 0.3
750 22 16 13 9.3 6.8 5.6 4.5 3.8 2.7 1.9 1.6 1.3 1.1 0.7 0.5 0.4

1,000 >25 19 16 11 8.1 6.8 5.2 4.5 3.1 2.3 2.2 1.5 1.3 0.8 0.6 0.4
1,500 * 23 19 13 9.9 8.1 6.8 5.6 3.9 2.9 2.4 1.9 1.6 1.0 0.7 0.6
2,000 * >25 22 15 12 9.3 7.4 6.8 4.5 3.4 2.7 2.2 1.9 1.2 0.8 0.6
2,500 * * 25 17 13 11 8.7 7.4 5.2 3.8 3.2 2.5 2.1 1.3 0.9 0.7
3,000 * * >25 19 14 12 9.3 8.1 5.7 4.2 3.5 2.8 2.4 1.4 1.0 0.8
4,000 * * * 22 17 14 11 9.3 6.8 4.9 4.1 3.3 2.8 1.7 1.1 0.9
5,000 * * * >25 19 16 12 11 7.4 5.6 4.7 3.7 3.1 2.1 1.3 1.1
7,500 * * * * 24 19 16 13 9.3 6.8 5.8 4.7 4.0 2.4 1.6 1.3
10,000 * * * * >25 22 18 16 11 8.1 6.8 5.3 4.6 2.8 1.9 1.5
15,000 * * * * * >25 22 19 13 9.9 8.1 6.8 5.7 3.5 2.4 1.9
20,000 * * * * * * >25 22 16 11 9.3 7.4 6.8 4.0 2.8 2.2
50,000 * * * * * * * >25 24 18 15 12 10 6.5 4.5 3.6
75,000 * * * * * * * * >25 22 18 15 13 7.8 5.4 4.4
100,000 * * * * * * * * * >25 21 17 14 8.9 6.3 5.0
150,000 * * * * * * * * * * >25 20 17 11 7.4 6.0
200,000 * * * * * * * * * * * 23 19 12 8.5 6.8

Annex 7
359
360
REFERENCE TABLE 19
Annex 7

Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 0.5 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 # # # # # # #
2 0.8 0.6 0.5 0.3 0.2 0.2 0.2 0.1 0.1 <0.1 <0.1 <0.1 # # # #
5 1.6 1.0 0.8 0.5 0.4 0.3 0.2 0.2 0.2 0.1 0.1 0.1 <0.1 # # #
10 2.0 1.4 1.2 0.8 0.6 0.5 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 <0.1 #
30 4.0 2.8 2.2 1.5 1.1 0.9 0.7 0.6 0.4 0.3 0.2 0.2 0.2 0.1 0.1 <0.1
50 5.5 3.9 3.1 2.1 1.5 1.2 1.0 0.8 0.6 0.4 0.3 0.3 0.2 0.1 0.1 0.1
100 8.7 6.1 4.8 3.2 2.2 1.8 1.4 1.2 0.8 0.6 0.5 0.4 0.3 0.2 0.1 0.1
150 12 8.1 6.2 4.1 2.9 2.3 1.8 1.6 1.1 0.7 0. 6 0.5 0.4 0.3 0.2 0.1
250 17 11 8.7 5.6 4.0 3.2 2.5 2.1 1.4 1.1 0.9 0.7 0.9 0.5 0.4 0.3
500 >25 19 14 9.3 6.2 5.0 3.9 3.3 2.2 1.6 1.3 1.0 0.9 0.5 0.4 0.3
750 * 25 19 12 8.7 6.8 5.1 4.2 2.8 2.0 1.6 1.3 1.1 0.6 0.4 0.4
1,000 * >25 24 15 11 8.1 6.1 5.2 3.4 2.4 1.9 1.5 1.3 0.7 0.5 0.4
1,500 * * >25 20 14 11 8.1 6.8 4.3 3.0 2.5 1.9 1.7 1.0 0.7 0.5
2,000 * * * 24 17 13 9.9 8.1 5.2 3.7 2.9 2.3 1.9 1.2 0.7 0.6
2,500 * * * >25 19 15 12 9.3 6.0 4.3 3.4 2.7 2.2 1.3 0.9 0.7
3,000 * * * * 22 17 13 11 6.8 4.8 3.8 3.0 2.5 1.5 1.0 0.8
4,000 * * * * >25 21 16 14 8.7 5.8 4.7 3.6 3.0 1.7 1.2 0.9
5,000 * * * * * 25 19 16 9.9 6.8 5.3 4.1 3.5 2.0 1.4 1.1
7,500 * * * * * >25 25 20 13 9.3 6.8 5.4 4.5 2.6 1.7 1.4
10,000 * * * * * * >25 25 16 11 8.7 6.8 5.4 3.1 2.1 1.6
15,000 * * * * * * * >25 21 14 11 8.7 7.4 4.0 2.6 2.1
20,000 * * * * * * * * 25 17 14 11 8.7 4.8 3.1 2.5
50,000 * * * * * * * * >25 >25 25 19 16 8.8 5.6 4.3

75,000 * * * * * * * * * * >25 25 20 11 7.3 5.6
100,000 * * * * * * * * * * * >25 24 14 9.4 6.8
150,000 * * * * * * * * * * * * >25 17 11 8.7
200,000 * * * * * * * * * * * * * 20 13 10

REFERENCE TABLE 20
Release Toxic End point (mg/L)
Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 0.5 0.3 0.2 0.2 0.1 0.1 0.1 0.1 <0.1 # # # # # # #
2 0.7 0.5 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 <0.1 # # # # #
5 1.1 0.8 0.6 0.5 0.3 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 <0.1 # # #
10 2.1 1.2 1.0 0.7 0.5 0.4 0.3 0.3 0.2 0.1 0.1 0.1 0.1 <0.1 # #
30 3.0 2.2 1.9 1.2 0.9 0.8 0.6 0.6 0.4 0.3 0.2 0.2 0.1 0.1 <0.1 #
50 4.1 3.0 2.5 1.6 1.2 1.0 0.8 0.7 0.5 0.3 0.3 0.2 0.2 0.1 0.1 <0.1
100 5.8 4.3 3.5 2.7 1.8 1.4 1.2 1.0 0.7 0.6 0.4 0.4 0.3 0.2 0.1 0.1
150 7.4 5.5 4.5 3.1 2.2 1.9 1.4 1.2 0.9 0.7 0.6 0.4 0.4 0.2 0.2 0.1
250 9.9 7.4 5.8 4.1 3.0 2.5 2.0 1.7 1.1 0.9 0.7 0.6 0.5 0.3 0.2 0.1
500 14 11 8.7 5.9 4.3 3.6 2.9 2.5 1.7 1.2 1.0 0.8 0.7 0.4 0.3 0.2
750 17 13 11 7.4 5.5 4.5 3.6 3.1 2.1 1.6 1.2 1.0 0.9 0.5 0.4 0.3

1,000 20 15 12 8.7 6.2 5.3 4.3 3.5 2.5 1.8 1.5 1.2 1.0 0.6 0.4 0.3
1,500 >25 19 16 11 8.1 6.2 5.2 4.5 3.0 2.2 1.8 1.5 1.2 0.7 0.5 0.4
2,000 * 22 18 12 9.3 7.4 6.2 5.2 3.7 2.7 2.2 1.7 1.4 0.9 0.6 0.5
2,500 * 24 20 14 11 8.7 6.8 6.0 3.8 3.0 2.2 1.9 1.7 1.0 0.7 0.6
3,000 * >25 22 16 11 9.3 7.4 6.8 4.5 3.3 2.7 2.1 1.9 1.1 0.7 0.6
4,000 * * >25 18 14 11 8.7 7.4 5.3 4.0 3.2 2.6 2.1 1.2 0.9 0.7
5,000 * * * 20 15 12 9.9 8.7 5.8 4.4 3.6 2.9 2.4 1.4 0.9 0.7
7,500 * * * >25 19 16 12 11 7.4 5.5 4.5 3.6 3.0 1.8 1.2 0.9
10,000 * * * * 22 18 14 12 8.7 6.2 5.2 4.2 3.6 2.1 1.4 1.1
15,000 * * * * >25 22 18 16 11 8.1 6.8 5.2 4.4 2.6 1.7 1.3
20,000 * * * * * >25 20 18 12 9.3 7.4 6.0 5.2 3.0 2.0 1.6
50,000 * * * * * * >25 >25 20 15 12 9.7 8.3 5.0 3.3 2.6
75,000 * * * * * * * * 25 18 15 12 10 6.1 4.1 3.1
100,000 * * * * * * * * >25 21 17 14 12 7.0 4.7 3.7
150,000 * * * * * * * * * >25 21 17 14 8.5 5.7 4.5
200,000 * * * * * * * * * * 24 19 16 9.7 6.5 5.1
Annex 7

361
362
REFERENCE TABLE 21
Annex 7

Rate 0.0004 0.0007 0.001 0.002 0.0035 0.005 0.0075 0.01 0.02 0.035 0.05 0.075 0.1 0.25 0.5 0.75
(lbs/
1 0.4 0.3 0.2 0.2 0.1 0.1 0.1 <0.1 # # # # # # # #
2 0.7 0.5 0.4 0.2 0.2 0.2 0.1 0.1 <0.1 <0.1 # # # # # #
5 1.1 0.8 0.7 0.4 0.3 0.2 0.2 0.2 0.1 0.1 <0.1 <0.1 <0.1 # # #
10 1.7 1.2 1.0 0.7 0.5 0.4 0.3 0.3 0.2 0.1 0.1 0.1 0.1 <0.1 # #
30 3.3 2.4 1.9 1.3 0.9 0.7 0.6 0.5 0.3 0.2 0.2 0.2 0.1 0.1 <0.1 #
50 4.7 3.3 2.6 1.7 1.2 1.0 0.8 0.7 0.4 0.3 0.3 0.2 0.2 0.1 0.1 <0.1
100 7.4 5.2 4.1 2.7 1.9 1.5 1.2 1.0 0.7 0.5 0.4 0.3 0.3 0.2 0.1 0.1
150 9.9 6.8 5.3 3.4 2.4 1.9 1.5 1.3 0.9 0.6 0.5 0.4 0.3 0.2 0.1 0.1
250 14 9.3 7.4 4.7 3.4 2.7 2.1 1.7 1.1 0.8 0.7 0.5 0.4 0.3 0.2 0.1
500 22 16 12 7.4 5.2 4.2 3.2 2.7 1.7 1.2 1.0 0.8 0.7 0.4 0.2 0.2
750 >25 20 16 9.9 6.8 5.4 4.2 3.5 2.2 1.6 1.3 1.0 0.9 0.5 0.3 0.3
1,000 * 24 19 12 8.1 6.8 5.0 4.2 2.7 1.8 1.6 1.2 1.0 0.6 0.4 0.3
1,500 * >25 >25 16 11 8.7 6.8 5.5 3.5 1.9 2.0 1.6 1.3 0.7 0.5 0.4
2,000 * * * 19 14 11 8.1 6.8 4.2 3.0 2.2 1.9 1.6 0.9 0.6 0.4
2,500 * * * 23 16 12 9.3 7.4 4.9 3.4 2.7 2.1 1.7 1.0 0.6 0.5
3,000 * * * >25 18 14 11 8.7 5.5 3.8 3.0 2.4 2.0 1.1 0.7 0.6
4,000 * * * * 22 17 13 11 6.8 4.7 3.1 2.8 2.4 1.3 0.9 0.7
5,000 * * * * >25 20 16 12 8.1 5.3 4.3 3.3 2.7 1.5 1.0 0.7
7,500 * * * * * 25 20 17 11 6.8 5.6 4.3 3.5 2.0 1.2 0.9
10,000 * * * * * >25 24 20 13 8.7 6.8 5.2 4.3 2.4 1.5 1.1
15,000 * * * * * * >25 >25 17 11 8.7 6.8 5.6 3.0 1.9 1.5
20,000 * * * * * * * * 20 14 11 8.1 6.8 3.6 2.3 1.7

50,000 * * * * * * * * >25 >25 20 15 13 6.6 4.0 3.1
75,000 * * * * * * * * * * >25 20 16 8.7 5.3 3.9
100,000 * * * * * * * * * * * 24 20 10 6.3 4.7
150,000 * * * * * * * * * * * >25 >25 14 8.2 6.1
200,000 * * * * * * * * * * * * * 16 9.9 7.3

Annex 7
REFERENCE TABLE 22
Distances to Toxic Endpoint for Anhydrous Ammonia
Liquefied Under Pressure
<10 <0.1* 900 0.6 0.2
10 0.1 1,000 0.6 0.2
15 0.1 1,500 0.7 0.3
20 0.1 <0.1* 2,000 0.8 0.3
30 0.1 2,500 0.9 0.3
40 0.1 3,000 1.0 0.4
50 0.1 4,000 1.2 0.4
60 0.2 0.1 5,000 1.3 0.5
70 0.2 0.1 7,500 1.6 0.5
80 0.2 0.1 10,000 1.8 0.6
90 0.2 0.1 15,000 2.2 0.7
100 0.2 0.1 20,000 2.5 0.8
150 0.2 0.1 25,000 2.8 0.9
200 0.3 0.1 30,000 3.1 1.0
250 0.3 0.1 40,000 3.5 1.1
300 0.3 0.1 50,000 3.9 1.2
400 0.4 0.2 75,000 4.8 1.4
500 0.4 0.2 100,000 5.4 1.6
600 0.5 0.2 150,000 6.6 1.9
700 0.5 0.2 200,000 7.6 2.1
750 0.5 0.2 250,000 8.4 2.3
800 0.5 0.2
*Report distance as 0.1 mile

Annex 7
REFERENCE TABLE 23
Distances to Toxic Endpoint for Non-liquefied Ammonia,
Ammonia Liquefied by Refrigeration,
or Aqueous Ammonia
<8 <0.1* 1,000 0.8 0.3
8 0.1 1,500 1.0 0.4
10 0.1 2,000 1.2 0.4
15 0.1 <0.1* 2,500 1.2 0.4
20 0.1 3,000 1.5 0.5
30 0.1 4,000 1.8 0.6
40 0.1 5,000 2.0 0.7
50 0.2 0.1 7,500 2.2 0.7
60 0.2 0.1 10,000 2.5 0.8
70 0.2 0.1 15,000 3.1 1.0
80 0.2 0.1 20,000 3.6 1.2
90 0.2 0.1 25,000 4.1 1.3
100 0.2 0.1 30,000 4.4 1.4
150 0.3 0.1 40,000 5.1 1.6
200 0.3 0.1 50,000 5.8 1.8
250 0.4 0.2 75,000 7.1 2.2
300 0.4 0.2 100,000 8.2 2.5
400 0.4 0.2 150,000 10 3.1
500 0.5 0.2 200,000 12 3.5
600 0.6 0.2
700 0.6 0.2
750 0.6 0.2

Annex 7
REFERENCE TABLE 24
Distances to Toxic Endpoint for Chlorine
1 <0.1* 750 1.2 0.4
2 0.1 <0.1* 800 1.2 0.5
5 0.1 1,000 1.3 0.5
10 0.2 0.1 1,500 1.6 0.6
15 0.2 0.1 2,000 1.8 0.6
20 0.2 0.1 2,500 2.0 0.7
30 0.3 0.1 3,000 2.2 0.8
40 0.3 0.1 4,000 2.5 0.8
50 0.3 0.1 5,000 2.8 0.9
60 0.4 0.2 7,500 3.4 1.2
70 0.4 0.2 10,000 3.9 1.3
80 0.4 0.2 15,000 4.6 1.6
90 0.4 0.2 20,000 5.3 1.8
100 0.5 0.2 25,000 5.9 2.0
150 0.6 0.2 30,000 6.4 2.1
200 0.6 0.3 40,000 7.3 2.4
250 0.7 0.3 50,000 8.1 2.7
300 0.8 0.3 75,000 9.8 3.2
400 0.8 0.4 100,000 11 3.6
500 1.0 0.4 150,000 13 4.2
600 1.0 0.4 200,000 15 4.8
700 1.1 0.4

Annex 7
REFERENCE TABLE 25
Distances to Toxic Endpoint for Sulfur Dioxide
1 <0.1* 750 1.3 0.5
2 0.1 <0.1* 800 1.3 0.5
5 0.1 900 1.4 0.5
10 0.2 0.1 1,000 1.5 0.5
15 0.2 0.1 1,500 1.9 0.6
20 0.2 0.1 2,000 2.2 0.7
30 0.2 0.1 2,500 2.3 0.8
40 0.3 0.1 3,000 2.7 0.8
50 0.3 0.1 4,000 3.1 1.0
60 0.4 0.2 5,000 3.3 1.1
70 0.4 0.2 7,500 4.0 1.3
80 0.4 0.2 10,000 4.6 1.4
90 0.4 0.2 15,000 5.6 1.7
100 0.5 0.2 20,000 6.5 1.9
150 0.6 0.2 25,000 7.3 2.1
200 0.6 0.2 30,000 8.0 2.3
250 0.7 0.3 40,000 9.2 2.6
300 0.8 0.3 50,000 10 2.9
400 0.9 0.4 75,000 13 3.5
500 1.0 0.4 100,000 14 4.0
600 1.1 0.4 150,000 18 4.7
700 1.2 0.4 200,000 20 5.4

Annex 7
REFERENCE TABLE 26
Neutrally Buoyant Plume Distances to

Lower Flammability Limit (LFL) for Release Rate Divided by LFL
Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second

0 - 28 0.1 2,700 - 3,300 0.9

28 - 40 0.1 3,300 - 3,900 1.0
40 - 60 0.1 3,900 - 4,500 1.1
60 - 220 0.2 4,500 - 5,200 1.2
220 - 530 0.3 5,200 - 5,800 1.3
530 - 860 0.4 5,800 - 6,800 1.4
860 - 1,300 0.5 6,800 - 8,200 1.6
1,300 - 1,700 0.6 8,200 - 9,700 1.8
1,700 - 2,200 0.7 9,700 - 11,000 2.0
2,200 - 2,700 0.8 11,000 - 13,000 2.2
REFERENCE TABLE 27

Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second

0 - 68 0.1 5,500 - 7,300 0.7

68 - 100 0.1 7,300 - 9,200 0.8
100 - 150 0.1 9,200 - 11,000 0.9
150 - 710 0.2 11,000 - 14,000 1.0
710 - 1,500 0.3 14,000 - 18,000 1.2
1,500 - 2,600 0.4 18,000 - 26,000 1.4
2,600 - 4,000 0.5 26,000 - 31,000 1.6
4,000 - 5,500 0.6 31,000 - 38,000 1.8

Annex 7
REFERENCE TABLE 27

Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second

0 - 68 0.1 5,500 - 7,300 0.7

68 - 100 0.1 7,300 - 9,200 0.8
100 - 150 0.1 9,200 - 11,000 0.9
150 - 710 0.2 11,000 - 14,000 1.0
710 - 1,500 0.3 14,000 - 18,000 1.2
1,500 - 2,600 0.4 18,000 - 26,000 1.4
2,600 - 4,000 0.5 26,000 - 31,000 1.6
4,000 - 5,500 0.6 31,000 - 38,000 1.8
REFERENCE TABLE 29
Dense Gas Distances to Lower Flammability
Limit
Urban Conditions,
D Stability, Wind Speed
3.0 Meters per Second
Lower Flammability Limit (mg/L)
Release Rate
27 30 35 40 >40
(lbs/min)
Distance (Miles)
<5,000 # # # # #
5,000 <0.1 <0.1 # # #
7,500 0.1 0.1 <0.1 # #
10,000 0.1 0.1 0.1 <0.1 #

REFERENCE TABLE 30
Distance to Radiant Heat Dose at Potential Second Degree Burn Threshold Assuming
Exposure for Duration of Fireball from BLEVE (Dose = [5 kW/m2]4/ 3 x Exposure Time)
Quantity in Fireball (pounds) 1,000 5,000 10,000 20,000 30,000 50,000 75,000 100,000 200,000 300,000 500,000
Duration of Fireball (seconds) 3.5 5.9 7.5 9.4 10.8 12.7 14.8 15.5 17.4 18.7 20.3
CAS No. Chemical Name Distance (miles) at which Exposure for Duration of Fireball May Cause Second Degree Burns
75-07-0 Acetaldehyde 0.04 0.08 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.6
74-86-2 Acetylene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
598-73-2 Bromotrifluoroethylene 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.1 0.1 0.2
106-99-0 1,3-Butadiene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
106-97-8 Butane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
106-98-9 1-Butene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
107-01-7 2-Butene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8

25167-67-3 Butene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
590-18-1 2-Butene-cis 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
624-64-6 2-Butene-trans 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
463-58-1 Carbon oxysulfide 0.02 0.05 0.06 0.09 0.1 0.1 0.2 0.2 0.2 0.3 0.3
7791-21-1 Chlorine monoxide 0.01 0.02 0.02 0.03 0.03 0.04 0.05 0.06 0.08 0.09 0.1
460-19-5 Cyanogen 0.03 0.07 0.1 0.1 0.2 0.2 0.2 0.3 0.4 0.4 0.5
75-19-4 Cyclopropane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
4109-96-0 Dichlorosilane 0.02 0.04 0.06 0.08 0.1 0.1 0.2 0.2 0.2 0.3 0.3
75-37-6 Difluoroethane 0.02 0.05 0.07 0.1 0.1 0.1 0.2 0.2 0.3 0.3 0.4
124-40-3 Dimethylamine 0.04 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.5 0.7
463-82-1 2,2-Dimethylpropane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
74-84-0 Ethane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
107-00-6 Ethyl acetylene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
75-04-7 Ethylamine 0.04 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.5 0.7
75-00-3 Ethyl chloride 0.03 0.07 0.09 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5
74-85-1 Ethylene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
Annex 7
369
370
REFERENCE TABLE 30 — CONTINUED
Annex 7
Duration of Fireball (seconds) 3.5 5.9 7. 5 9.4 10.8 12.7 14.8 15.5 17.4 18.7 20.3
60-29-7 Ethyl ether 0.04 0.09 0.1 0.2 0.2 0.2 0.3 0.3 0.5 0.5 0.7
75-08-1 Ethyl mercaptan 0.04 0.08 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5 0.6
109-95-5 Ethyl nitrite 0.03 0.06 0.09 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.5
1333-74-0 Hydrogen 0.08 0.2 0.2 0.3 0.4 0.5 0.6 0.6 0.9 1.0 1.2
75-28-5 Isobutane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
78-78-4 Isopentane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
78-79-5 Isoprene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.7
75-31-0 Isopropylamine 0.04 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.6 0.7
75-29-6 Isopropyl chloride 0.04 0.07 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.4 0.5
74-82-8 Methane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.6 0.6 0.8
74-89-5 Methylamine 0.04 0.08 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5 0.6
563-45-1 3-Methyl-1-butene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
563-46-2 2-Methyl-1-butene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.7
115-10-6 Methyl ether 0.04 0.08 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5 0.6
107-31-3 Methyl formate 0.03 0.06 0.08 0.1 0.1 0.2 0.2 0.2 0.3 0.4 0.4
115-11-7 2-Methylpropene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
504-60-9 1,3-Pentadiene 0.05 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.6 0.7
109-66-0 Pentane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
109-67-1 1-Pentene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
646-04-8 2-Pentene, (E)- 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
627-20-3 2-Pentene, (Z)- 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
463-49-0 Propadiene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8

74-98-6 Propane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
115-07-1 Propylene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
74-99-7 Propyne 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
REFERENCE TABLE 30 — END
Duration of Fireball (seconds) 3.5 5.9 7. 5 9.4 10.8 12.7 14.8 15.5 17.4 18.7 20.3
7803-62-5 Silane 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.7
116-14-3 Tetrafluoroethylene 0.01 0.02 0.02 0.03 0.04 0.05 0.06 0.07 0.09 0.1 0.1
75-76-3 Tetramethylsilane 0.05 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.6 0.7
10025-78-2 Trichlorosilane 0.01 0.03 0.04 0.06 0.07 0.08 0.1 0.1 0.2 0.2 0.2
79-38-9 Trifluorochloroethylene 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.1 0.1 0.2

75-50-3 Trimethylamine 0.04 0.09 0.1 0.2 0.2 0.3 0.3 0.4 0.5 0.6 0.7
689-97-4 Vinyl acetylene 0.05 0.1 0.1 0.2 0.2 0.3 0.4 0.4 0.5 0.6 0.8
75-01-4 Vinyl chloride 0.03 0.07 0.09 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5
109-92-2 Vinyl ethyl ether 0.04 0.09 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5 0.6
75-02-5 Vinyl fluoride 0.01 0.02 0.03 0.04 0.05 0.06 0.08 0.09 0.1 0.1 0.2
75-35-4 Vinylidene chloride 0.02 0.05 0.07 0.09 0.1 0.1 0.2 0.2 0.3 0.3 0.4
75-38-7 Vinylidene fluoride 0.02 0.05 0.07 0.09 0.1 0.1 0.2 0.2 0.3 0.3 0.4
107-25-5 Vinyl methyl ether 0.04 0.08 0.1 0.2 0.2 0.2 0.3 0.3 0.4 0.5 0.6
Annex 7
371
Risk Management Plan Form
8
Annex
373
Annex 8
RISK MANAGEMENT PLAN FORM

I - Registration
1. Source Identification
a) Facility Name
b) Street
c) City
d) Postal Code
e) Latitude
f) Longitude
2. Owner or Operator
a) Name
b) Phone
c) Mail Address
3. Emergency Contact
a) Name
b) Title
c) Phone
d) 24-Hour Phone
4. Chemical(s)
5. CAS Number
6. Danger Level
7. Quantity
8. Brief Description of Operations
II - Toxics: Worst Case

(Complete one)
1. Chemical
2. Physical state
a) Gas
b) Liquid
c) Refrigerated gas
d) Compressed liquefied gas
3. Normalized scenario calculation
a) Model used
4. Scenario
a) Vessel failure
b) Pipe failure
c) Other (specify)
5. Quantity released (lbs)
6. Release rate (lbs/min)
7. Release duration if modeled (min)
8. Wind speed (m/s)

Annex 8
9. Stability class
10. Topography (check one)
a) Urban
b) Rural
11. Distance to endpoint (miles)
12. Population within distance
13. Sensitive areas - Public receptors (check all that apply)
a) Schools
b) Residences
c) Hospitals
d) Public recreational areas or arenas
e) Major commercial or industrial areas
f) Others
14. Environmental receptors within distance (check all that apply)
a) Ecological parks
b) Officially designated wildlife sanctuaries, preserves, or refuges
c) Potable water intake
d) Federal wilderness areas
e) Streams
f) Lakes
g) Aquifers
h) Others
15. Passive mitigation considered (check all that apply)
a) Dikes
b) Enclosures
c) Berms
d) Drains
e) Sumps
f) Other (specify)
III - Toxics: Alternative Releases

(Complete for each toxic)
1. Chemical
2. Physical state
a) Gas
b) Liquid
c) Refrigerated gas
3. Calculation of more likely scenario
a) Model used
4. Scenario
a) Transfer hose failure
b) Pipe leak
c) Vessel leak
d) Overfilling
e) Rupture disk/relief valve failure
f) Other (specify)
Annex 8

6. Release rate (lbs/min)
7. Release duration (min)
8. Wind speed (m/s)
9. Stability class
a) Urban
b) Rural
13. Public receptors (check all that apply)
a) Schools
b) Residences
c) Hospitals
f) Others
a) Ecological areas
d) Streams
e) Lakes
f) Aquifers
g) Others
a) Dikes
b) Other (specify)
16. Active mitigation considered (check all that apply)
a) Sprinkler systems
b) Deluge systems
c) Water curtain
d) Neutralization
e) Flares
f) Scrubbers
g) Emergency shutdown system
h) Other (specify)

Annex 8
IV - Flammables: Worst Case

(Complete one)
1. Chemical
2. State
a) Gas
b) Liquid
c) Refrigerated gas
3. Normalized scenario
a) Model used
4. Scenario
a) Vapor cloud explosion
b) Fireball/BLEVE
6. Release rate (lbs/s)
8. Wind speed (m/s)
9. Stability class
a) Urban
b) Rural
11. Endpoint used
a) Schools
b) Residences
c) Hospitals
f) Others
a) Ecological areas
d) Streams
e) Lakes
f) Aquifers
g) Others
a) Dikes
b) Fire walls
c) Blast walls
d) Other (specify)

Annex 8
V. Flammables: Alternative Releases

(Complete one)
1. Chemical
2. State
a) Gas
b) Liquid
c) Refrigerated gas
3. Results based on
Model used
4. Scenario
a) Vapor cloud explosion
b) Fireball
c) BLEVE
d) Pool fire
e) Jet fire
6. Release rate (lbs/s)
8. Wind speed (m/s)
9. Stability class
10. Topography (select one)
a) Urban
b) Rural
11. Endpoint used
a) Schools
b) Residences
c) Hospitals
f) Others
15. Environmental receptors within distance to endpoint (select all that apply)
a) Ecological areas
d) Streams
e) Lakes
f) Aquifers
g) Others

Annex 8
16. Passive mitigation considered (select all that apply)

a) Dikes
b) Fire walls
c) Blast walls
17. Active mitigation considered (select all that apply)
a) Sprinkler systems
b) Deluge systems
c) Water curtain
d) Flare
e) Other (specify)
Information Gathered during Site Visit
I - Five-year Accident History

(Complete the following for each release)
1. Date
2. Time
3. Release duration
4. Chemical(s)
5. Quantity released (kg)
6. Release event
a) Gas release
b) Liquid spill/evaporation
c) Fire
d) Explosion
e) Other (specify)
7. Release source
a) Storage vessel
b) Piping
c) Process vessel
d) Transfer hose
e) Valve
f) Pump
8. Weather conditions at time of event
a) Wind direction and speed
b) Temperature
c) Stability class
d) Precipitation present
e) Unknown weather conditions

Annex 8
9. On-site impacts
a) Death
b) Injuries
c) Property damage ($)
10. Known off-site impacts
a) Death
b) Hospitalizations
c) Other medical treatment
d) Evacuated
e) Sheltered
f) Property damage ($)
g) Environmental damage
11. Initiating event (select one)
a) Equipment failure
b) Human error
c) Weather condition
12. Contributing factors (select all that apply)
a) Equipment failure
b) Human error
c) Improper procedure
d) Overpressurization
e) Upset condition
f) By-pass condition
g) Maintenance activity/inactivity
h) Process design
i) Unsuitable equipment
j) Unusual weather conditions
k) Management error
13. Off-site responders notified (yes or no)
14. Changes introduced as a result of the accident (check at least one)
a) Improved/upgraded equipment
b) Revised maintenance
c) Revised training
d) Revised operating procedures
e) New process controls
f) New mitigation systems
g) Revised emergency response plan
h) Changed process
i) Reduced inventory

Annex 8
II - Prevention Program/Operational Security

(for each source)
1. Management — Do you have a management system that assigns responsibility
for implementation of the prevention program? a: yes ___ b: no ___.
2. Do you have up-to-date process safety information? a: yes ___ b: no ___.
a) Process descriptions, chemical reactions
b) Equipment description
c) Electrical classification
3. Do you have operation procedures for each covered process? a: yes ___ b: no ___.
4. Training — Do you have a training program? a: yes ___ b: no ___.
5. Mechanical integrity — Do you have a maintenance program that meets the
requirements of section 68.78? a: yes ___ b: no ___.
6. Pre-startup review — Do you have pre-startup review procedures and do you use
them when appropriate? a: yes ___ b: no ___.
7. Management of change — Do you have management of change procedures and
do you use them when appropriate? a: yes ___ b: no ___.
8. Compliance audits — When was the date of your last compliance audit?
9. Incident audits — Have you developed procedures for investigating accidents and
have you investigated them? a: yes ___ b: no ___.
10. Do you have an employee participation plan? a: yes ___ b: no ___.
11. Do you have hot work permits? a: yes ___ b: no ___.
III - Hazard Identification

1. Do you have Process Hazard Analysis completed?
a: yes ___ b: no ___ c: new ___ d: update ___.
a) Identify chemicals
2. If yes, check technique used
a) What If?
b) Checklist
c) What If/Checklist (combined)
d) HAZOP
e) Failure Mode & Effects Analysis
f) Fault Tree Analysis
g) Other (Specify)

Annex 8
3. Major hazards (check all that apply)

a) Toxic release
b) Fire
c) Explosion
d) Runaway reaction
e) Polymerization
f) Corrosion
g) Overfilling
h) Contamination
i) Equipment failure
j) Loss of cooling, heating, electricity, instrument air
k) Earthquake
l) Floods (flood plain)
m) Tornado
n) Hurricanes
o) Other
4. Process controls (check all that apply)
a) Vents
b) Relief valves
c) Check valves
d) Scrubbers
e) Flares
f) Manual shutoffs
g) Automatic shutoffs
h) Interlocks
i) Alarms and procedures
j) Keyed bypass
k) Emergency air supply
l) Emergency power
m) Backup pump
n) Grounding equipment
o) Inhibitor addition
p) Rupture disks
q) Excess flow device
r) Quench system
s) Purge system
t) Other
5. Mitigation systems (check all that apply)
a) Sprinkler system
b) Dikes
c) Fire walls
d) Blast walls
e) Deluge system
f) Water curtain
g) Enclosure
h) Neutralization
i) Other

Annex 8
6. Monitoring/detection systems (check all that apply)

a) Process area detectors
b) Perimeter monitors
c) Other
7. Changes since last hazard review or hazard review update (check all that apply)
a) Reduction in chemical inventory
b) Increase in chemical inventory
c) Change in process parameters
d) Installation of process controls
e) Installation of process detection systems
f) Installation of perimeter monitoring systems
g) Installation of mitigation systems
h) Other (specify)
i) None required/recommended

Selected Books and Software
9
Annex
385
Annex 9
Suggested Reference Books

• Guidelines for Chemical Process Quantitative Risk Analysis, American lnstitute of Chemical
Engineers, New York, NY, 1989.
• Guidelines for Process Equipment Reliability Data with Data Tables, American lnstitute of
Chemical Engineers, New York, NY, 1989.
• Guidelines for Hazard Evaluation Procedures Second Edition with Worked Examples,
American Institute of Chemical Engineers, New York, NY, 1992.
• Plant Guidelines for Technological Management of Chemical Process Safety, American
Institute of Chemical Engineers, New York, NY, 1992.
• Tools for Making Acute Risk Decisions with Chemical Process Safety Applications, American
Institute of Chemical Engineers, New York, NY, 1994.
• Guidelines for Evaluating the Characteristics of Vapor Cloud Explosions, Flash Fires and
BLEVEs, American Institute of Chemical Engineers, New York, NY, 1994.
• Guidelines for Preventing Human Error in Process Safety, American lnstitute of Chemical
Engineers, New York, NY, 1994.
• Loss Prevention in the Process Industries, Frank P. Lees, Butterworth Heinemann Ltd.,
London, U.K., 1980.
• Handbook of Chemical Hazard Analysis Procedures, FEMA, DOT, EPA, Washington, DC,
1989.
• Methods for the Calculation of Physical Effects, TNO, Directorate-General of Labour of the
Ministry of Social Affairs and Employment, The Hague, Netherlands, 1992.
• Methods for the Determination of Possible Damage, TNO, Directorate-General of Labour of
the Ministry of Social Affairs and Employment, The Hague, Netherlands, 1992.
Suggested Software
Software Applications Author Cost
ALOHA Modelling of National Oceanographic Free*

toxic plumes and Atmospheric
Administration, Seattle
RMP*Comp Modelling of EPA Free

accident scenarios
PHAST Consequences of DNV US$15 000

toxic clouds and Technica Houston
of explosions.
Sophisticated
software
* http://www.epa.gov/swercepp/cameo/request.htm

G
Glossary
389
Glossary
Alternative scenario
Represents the most serious accident that can occur for a listed hazardous material, held in
a quantity exceeding the threshold quantity. This scenario takes into account the proximity
or interconnection of the vessels containing the substance involved. However, it also takes
into account passive and active mitigation measures.
Analysis of accident consequences
Analysis of expected effects of an accident, regardless of frequency and probability factors
(BIT 1990) or (according to the CAN/CSA Q850-97 standard) an analysis of the effects of
various scenarios on the public and aspects affected by the activity.
BLEVE (Boiling Liquid, Expanding Vapour Explosion)
Occurs from the sudden release of a large mass of pressurized liquid to the atmosphere. A
primary cause is an external flame impinging on the shell of a vessel
1
above the liquid level,
weakening the shell and resulting in sudden rupture. (CCPS 2000)
Consequences (of an accident)
A measure of the expected effects of an accident.
Dense gas
A gas with density exceeding that of air at1 ambient temperature and which has a tenden-
cy to remain on the ground. (CCPS 2000)
ERPG-1 (Emergency Response Planning Guidelines 1)
Maximum airborne concentration below which it is believed that nearly all individuals could
be exposed for up to 1 hour without experiencing other than mild transient adverse health
effects or perceiving a clearly defined, objectionable odour. (AIHA 1988)
be exposed for up to 1 hour without experiencing or developing irreversible or other seri-
ous health effects or symptoms which could impair an individual’s ability to take protective
action. (AIHA 1988)
be exposed for up to 1 hour without experiencing or developing life-threatening health
effects. (AIHA 1988)
Explosion
Sudden, unexpected and significant release of pressure causing or capable of causing seri-
ous damage, fires or spills.
Fixed source
Any buildings, structures, equipment, installations, or substance emitting stationary activi-
ties which belong the same industrial group, which are located on one or more contiguous
properties, which are the under control of the same person (or persons under common
control), and from which an accidental release may occur.
Flash fire
The combustion of a flammable vapor and air mixture in which flame passes through that
mixture at less than sonic velocity, such that negligible damaging overpressure is generat-
ed. (CCPS 2000)

Glossary
Flash point
The lower temperature at which vapours above a volatile substance will ignite in air when
exposed to a flame.
Hazard
A chemical or physical situation with a potential for injury to people, property damage or
damage to the environment. This word also describes the nature of the phenomenon that
can cause damage: explosion, toxic gas leak, radioactivity, fire, water pollution, etc. When
a substance is added to certain matter, its undesirable properties surface (flammability, tox-
icity, corrosiveness, explosiveness, etc.).
Hazard level
Concentration of a hazardous material in the air following an emission, a thermal flux in
case of fire and/or a shockwave in case of explosion from which there can be serious and
irreversible damage to health and life.
Hazardous materials
Toxic, flammable, explosive or reactive substances found on the list of hazardous materials.
Identification of a hazard
Recognition of the presence of a hazard and the definition of its characteristics.
IDLH (Immediately Dangerous to Life or Health)
These values represent the maximum concentrations of hazardous materials to which a per-
son can be exposed for 30 minutes following the failure of a respiratory protection device
without suffering from any effects that would prevent the individual from vacating the
premises or without experiencing any irreversible health effects. (NIOSH 1990, p. 5)
Ignition point
Minimum temperature at which the vapours at the surface of a liquid or a solid will catch
fire and will continue to burn when the ignition source is removed.
Jet fire
Fire type resulting from fires from pressurized release of gas and/or liquid.
Joint Coordinating Committee
Committee made up of municipal administrations, industries likely to pose a major risk,
agencies that play a lead role in prevention and response during emergencies and repre-
sentatives of concerned citizens residing in the municipality. The committee’s goal is to har-
monize the prevention strategies and fight against major industrial accidents and initiate
dialogue with the community on this subject. (JCC of Montréal-Est 1995)
LEL (Lower explosive limit)
Minimum concentration of a gas below which the air/gas mix cannot burn or explode.
Major industrial accident
An unexpected and sudden event involving hazardous materials (release of toxic matter,
explosion, thermal radiation) and having consequences for the population and the environ-
ment outside the site of the establishment.
Neutrally buoyant gas
Gas or vapour whose density is approximately the same as that of air and which acts like
air.
Operational safety measure
Measure put in place to prevent accidents in facilities that manufacture, store, handle or use
hazardous materials.

Glossary
Passive mitigation measures

Systems intended to lessen the consequences of an accident on the public and the sensi-
tive areas that do not require human intervention, external mechanisms or energy sources.
(EPA 1996) Equipment, device or technology functioning without human or mechanical
intervention or other energy supports (sprinkler system, water curtain, valve, flare, etc.) (JCC
of Montréal-Est 1999)
Population
The public, namely all individuals except for employees or contractors on the site of an
industrial establishment.
Preparedness
Actions taken to establish the response capability and the mitigation of the effects of an
uncontrolled or accidental release.
Prevention (program)
Actions taken to anticipate, prevent or reduce the likelihood of an emission or an uncon-
trolled or accidental spill of a pollutant or hazardous material.
Prevention program
Program targeting the prevention of major industrial accidents by establishing operational
safety measures, implementing a harmonized approach and emergency response plans, as
well as communicating information to citizens on the safety measures taken by the munic-
ipalities and the companies and on how to protect themselves in case of accident.
Process
Any activity involving a regulated substance including any use, storage, manufacturing,
handling, or on-site movement of such substances, or combination of these activities. For
the purposes of this definition, any group of vessels that are interconnected, or separate
vessels that are located such that a regulated substance could be involved in a potential
release, shall be considered a single process.
Radius or impact zone
Sector inside which the concentration in air of a hazardous material involved in an accident
or the thermal flux or superpressure caused by a fire or explosion reaches the danger level.
(EPA/NOAA/NSC 1992)
Regulated substance
Toxic or flammable substance found on the List of Hazardous Materials in Annex 3.
Response
Measures adopted during an emergency that aim to control or slow down the leak of a
hazardous material in order to protect the population, the sensitive zones and the environ-
ment.
Risk
Probability that an emission will occur, taking into consideration the dangerous properties
of the chemical products combined with the quantity emitted and the potential impact of
the emission on the public and the environment.
Risk analysis
Systematic use of information that allows determining the hazards and evaluating the like-
lihood and the severity of harmful effects on individuals or populations (injuries or losses),
material goods, the environment and other valuables. (CAN/CSA Q850-97)

Glossary
Risk management
Systematic application of management guidelines, methods and practices in terms of analy-
sis, evaluation, control and disclosure of risks. (CAN/CSA Q850-97)
Sensitive areas
Elements external to a project or an establishment capable of being affected during an acci-
dent in such a way that the consequences could be increased (teaching institutions, hospi-
tals, residential district, potable water supply, ecological zones, specific natural sites, storage
areas for chemical products, communication lines, etc.). (MEF guideline for studies on the
repercussions of new projects)
Target establishment
Establishment that holds one or more hazardous materials contained on the List of
Hazardous Materials, whose maximum inventory at any given moment exceeds the thresh-
old quantity.
Threshold quantity
Maximum quantity of a regulated substance that the establishment can hold without being
subject to the process. These quantities are predetermined and appear on the List of
Hazardous Materials in Annex 3.
TLV (Threshold Limit Value)
Average concentration weighted over an 8-hour period or a 40-hour workweek, and to
which almost all workers can be repeatedly exposed, day after day, without any harmful
effect.
Toxic endpoint
Fixed maximum concentration for a toxic substance in mg/litre or in ppm.
UEL (Upper explosive limit)
Concentration above which the air/gas mix cannot burn or explode.
Vapour cloud explosion (VCE)
When a flammable vapor is released, its mixture with air will form a flammable vapour
cloud. If ignited, the flame may accelerate to high velocities and produce significant blast
overexposure. (CCPS 2000)
Vessel
Any reactor, reservoir, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose or other con-
tainer.
Worst-case release scenario
This accident scenario represents the release of the greatest quantity of a hazardous sub-
stance, held in the largest container, whose impact distance is the greatest.

Glossary
List of Acronyms and Abbreviations
ACGIH American Conference of Governmental Industrial Hygienists

AIChE American Institute of Chemical Engineers
ALOHA Areal Locations of Hazardous Atmospheres
API American Petroleum Institute
BLEVE Boiling Liquid, Expanding Vapour Explosion
CAA Clean Air Act
CAS Chemical Abstracts Service
CCPS Center for Chemical Process Safety
CFR Code of Federal Regulations (U.S.)
CMA Chemical Manufacturers Association
CSST Commission de la santé et de la sécurité du travail au Québec
EIA Environmental Impact Assessment
EPA United States Environmental Protection Agency (U.S.)
EPCRA Emergency Planning and Community Right-to-Know Act
ERPG Emergency Response Planning Guideline
FMEA Failure Mode and Effects Analysis
FTA Fault Tree Analysis
HAZOP Hazard and Operability Analysis
HAZWOPER Hazardous Waste Operations and Emergency Response
ICP Integrated Contingency Plan
JCC Joint Coordinating Committee
kPa kilopascal
kW/m2 kilowatt per square metre
lb/min pound per minute
LEPC Local Emergency Planning Committee
MEF Ministère de l’Environnement et de la Faune du Québec
mg/L milligram per litre
mg/m3 milligram per cubic metre
MIACC Major Industrial Accidents Council of Canada
MSP Ministère de la Sécurité publique
MOC Management of Change
NFPA National Fire Protection Association
NOAA National Oceanographic and Atmospheric Administration
NRT National Response Team
OSHA Occupational Safety and Health Administration
PFD Process Flow Diagram
PHA Process Hazard Analysis
P&ID Process and Instrumentation Diagram
ppm parts per million
psi pound per square inch
psia pound per square inch absolute
psig pound per square inch gauge
PSM Process Safety Management
RMP Risk Management Program
SERC State Emergency Response Commission
UN United Nations
WHAZAN World Bank Hazards Analysis
WHMIS Workplace Hazardous Materials Information System

R
References
397
References
• AIHA (1988), Emergency Response Planning Guidelines, American Industrial Hygiene

Association, Fairfax, VA, 1988.
• BIT (1990)
• CAN/CSA-Q850-97, Management of Risks: Guide Intended for Decision-Makers, Ontario,
1997.
• CAN/CSA-Z731-95, Planning Emergency Measures for Industry, Ontario, 1995.
• CCPA, Site Self-Evaluation Tools, Ottawa, 1999.
• CCPS (1989a), Guidelines for Process Equipment Reliability Data with Data Tables, American
Institute of Chemical Engineers, New York, N.Y., 1989.
• CCPS (1989b), Guidelines for Chemical Process Quantitative Risk Analysis, American Institute
of Chemical Engineers, New York, N.Y., 1989.
• CCPS (1992a), Guidelines for Hazard Evaluation Procedures, Second Edition with Worked
Examples, American Institute of Chemical Engineers, New York, N.Y., 1992.
• CCPS (1992b), Plant Guidelines for Technological Management of Chemical Process Safety,
American Institute of Chemical Engineers, New York, N.Y., 1994.
• CCPS (1994), Tools for Making Acute Risk Decisions with Chemical Process Safety
Applications, American Institute of Chemical Engineers, New York, N.Y., 1994.
• CCPS 2000, Guidelines for Chemical Process Quantitative Risk Analysis Second Edition
(American Institute of Chemical Engineers) (ISBN 0-8169-0720-X)
• Commission of the European Communities (1994), Proposal for a Council Directive on the
Control of Major Accident Hazards Involving Dangerous Substances (COMAH), Luxembourg,
Office for Official Publications of the European Communities.
• Council of European Communities (1982), Seveso Directive, 82/5011CEE.
• CSST, Planification des mesures d’urgence pour assurer la sécurité des travailleurs.
• DGSC (1994a), La sécurité civile au Québec, Manuel de base, Sainte-Foy, Québec.
• DGSC (1994b), La sécurité publique au Québec, Manuel de base, Sainte-Foy, Québec.
• EPA (1994), List of Regulated Substances and Thresholds for Accidental Release Preventions
(40 CFR Part 68), Federal Register, Washington, January 31, 1994.
• EPA (1995), Risk Management Programs for Chemical Accidental Release Prevention: Proposed
Rule (40 CFR Part 68), Federal Register, Washington, D.C., March 13, 1995.
• EPA (1996)
• EPA (1998), General Guidance for Risk Management Programs (40 CFR Part 68), Washington,
D.C.,1998.
• EPA (1999), Risk Management Program Guidance for Offsite Consequence Analysis,
Washington, D.C., April 15, 1999.
• EPA/NOAAI/NSC (1992), User’s Manual of CAMEO, Washington, D.C., 1992.
• ILO (1990), Preventing Major Industrial Accidents, International Labour Office, Geneva,
Switzerland, 1990.
• JCC of Montréal-Est (1995)
• JCC of Montréal-Est (1999a), Analyse et gestion d’accidents industriels majeurs, volume 1,
Québec. 1999. (Joint Coordinating Committee of Montréal-Est, Analysis and Management of
Major Industrial Accidents, Volume 1, Quebec, 1999a)
• JCC of Montréal-Est (1999b), Analyse et gestion d’accidents industriels majeurs, volume 2,
Québec. 1999. (Joint Coordinating Committee of Montréal-Est, Analysis and Management of
Major Industrial Accidents, Volume 2, Quebec, 1999b)

References
• Lees, F.P. and Ang, M.L. (1989), Safety Cases, Butterworth-Heinemann, London, U.K., 1989.
• Law on the Protection of Persons and Goods in Case of Disaster, R.S.Q., c. p-38.1, art. 11
• Law on Public Health, R.S.Q. c. p-35, art. 17, 18.
• Law on Workers’ Health and Safety.
• MIACC (1993), Guidelines for Joint Municipal and Industrial Emergency Measures Preparation,
Ottawa, 1993.
• MIACC (1994)
• MSPQ (1994)
• NIOH (1990)
400
Membership Form
M
Membership
401
Membership Form
Membership Form
827 Crémazie Boulevard East, suite 350

Montréal, Québec H2M 2T8
Fax: (514) 280-4044
Name of Organization
(Business, municipality, association, department, public agency)
Address
Tel. ( ) Fax ( )
E-mail address
ANNUAL FEES : $250/MEMBER
Members’ name
Name Signature
(in print letters)
Title Date
Please invoice me ❑ Cheque enclosed ❑
Please return this form

by mail at:
Conseil pour la réduction des accidents industriels majeurs (CRAIM)
827 Crémazie Boulevard East, suite 350, Montréal, Québec H2M 2T8
by e-mail at: Ginette Joly, Treasurer of CRAIM - ginettejoly@sympatico.ca
or by fax at: 514-280-4044
✄

827, Crémazie Boulevard East, Suite 350
Montréal Québec H2M 2T8

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2 Risk Management Guide for Major Industrial Accidents

Montréal, June 2002

Risk Management Guide for Major Industrial Accidents 5

UNEP's APELL programme

UNEP's APELL programme

6 Risk Management Guide for Major Industrial Accidents

Craim Mission Statement

Risk Management Guide for Major Industrial Accidents 7

Risk Management Guide for Major Industrial Accidents 9

Risk Management Guide for Major Industrial Accidents 13

14 Risk Management Guide for Major Industrial Accidents

Identifying the Issues

Risk Management Guide for Major Industrial Accidents 17

∆ implement an emergency plan conforming with the CAN/CSA-Z731-95 and NFPA

Implement a Joint Coordinating Committee (JCC)

18 Risk Management Guide for Major Industrial Accidents

Risk Management Guide for Major Industrial Accidents 21

Approach for the Analysis of Risks

Step 1 – Establishments at Potential Risk

Step 2 – Target Establishments

22 Risk Management Guide for Major Industrial Accidents

LOCATIONS HAZARDOUS MATERIALS

1. Large storage or combustible-processing

2. Transport of petroleum or gasoline

3. Large cooling facilities

5. Specific basic products

Risk Management Guide for Major Industrial Accidents 23

LOCATIONS HAZARDOUS MATERIALS

7. Specific chemical products

24 Risk Management Guide for Major Industrial Accidents

LOCATIONS HAZARDOUS MATERIALS

• Production and storage of explosives . . . . . . . . . . . . . .Explosives, nitric acid, TNT, ANFO

11. Public areas and services

• Drinking water filtration plant . . . . . . . . . . . . . . . . . . . .Chlorine

12. Pipelines except those used

13. Laundries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Chlorinated solvents

14. Centres for transferring,

15. PVC industries . . . . . . . . . . . . . . . . . . . . . . . . . . .Hydrogen chloride, chlorine, phosgene, dioxins

16. Storage sites for

17. Storage of PCBs, tires,

Risk Management Guide for Major Industrial Accidents 25

Step 3 – Analysis of the Accident Consequences

26 Risk Management Guide for Major Industrial Accidents

Risk Management Guide for Major Industrial Accidents 27

Alternative Process safety Communications

28 Risk Management Guide for Major Industrial Accidents

TOXIC GASES AND LIQUIDS

Toxic substances from the list appearing in gaseous form at 25°C.

Toxic gases liquefied by refrigeration

Instantaneous emission of a gas liquefied by refrigeration.

Instantaneous emission of a toxic liquid.

Risk Management Guide for Major Industrial Accidents 29

FLAMMABLE AND EXPLOSIVE GASES AND LIQUIDS2

Substances stored in gaseous or liquid state under pressure

Flammable gases liquefied by refrigeration (cryogenics) at atmospheric pressure

Instantaneous emission of the total mass of liquefied gas.

Instantaneous emission of the total mass of flammable liquid.

30 Risk Management Guide for Major Industrial Accidents

Step 4 – Review of Accidents over a Five-year Period