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U.S. EPA: Risk management, Response is key


The U.S. Environmental Protection Agency has waived penalties against the Swiss American Sausage Company, a subsidiary of Hormel Food Corporation, located in Lathrop, Calif., after the facility voluntarily reported federal Clean Air Act Risk Management Program violations.

“The EPA is pleased with the responsible action taken by the Swiss American Sausage Company -- it’s the responsibility of all companies to do the required reporting,“ said Keith Takata, Superfund Division director in the EPA’s Pacific Southwest region. ”It’s critical that facilities using chemicals follow our chemical accident prevention rules to protect the health and safety of area residents, emergency response personnel, and the environment"

The San Joaquin County-based food storage and distribution facility voluntarily disclosed to the EPA that it had not submitted a risk management plan, as required by the Clean Air Act. Swiss American Sausage self-disclosed the violations in accordance with EPA’s Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations Policy, commonly referred to as the ‘audit policy.’ The EPA has the discretion to eliminate penalties if it determines that a respondent has satisfied certain conditions set forth in the audit policy.

Federal regulations require all facilities using hazardous substances above specified thresholds to develop chemical risk management plans. Risk management plans help prevent chemical releases and prompt detection and response when chemical releases do occur. At this facility, at least 16,000 pounds of anhydrous ammonia used in the refrigeration system mandated a risk management plan.

The EPA may reduce penalties up to 100 percent for violations that are voluntarily discovered, promptly disclosed to the agency and quickly corrected. Swiss American Sausage very quickly corrected and self-disclosed its violation.

A risk management plan must include an assessment of the potential effects of an accidental release, history of accidents over the past five years and employee training. The plan must also include an emergency response program that outlines procedures for informing the public and response agencies, such as the police and fire departments, in the event of an accident.

The risk management program requires an emergency response strategy, evaluation of a worst case and probable case chemical release, and a prevention program that includes operator training, a review of the hazards associated with using toxic or flammable substances, operating procedures and equipment maintenance.


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