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You are not covered by the Risk Management Program. These WebPages DO NOT REPLACE RULE! The ultimate responsibility of complying with Clean Air Act Section 112(r) and the Accidental Release Prevention and Risk Management Planning Act falls on the owner or operator of the stationary source!
Although you are not covered under the Risk Management Program you still have to consider the General Duty Clause.
"The owners and
operators of stationary sources producing, processing, handling
or storing such substances have a general duty in the same manner
and to the same extent as section 654, title 29 of the United
States Code, to identify hazards which may result from such
releases using appropriate hazard assessment tech-
niques, to design and maintain a safe facility taking such steps
as are necessary to prevent releases, and to minimize the
consequences of accidental releases which do occur."
Excert from General Duty Clause Section
112(r)(1)