Implications of EPA's Risk Management Program to semiconductor manufacturers

The US EPA's Risk Management Program (RMP) requires consequences analyses of accidental releases, independent of the probability of release, for a list of toxic and flammable substances. The General Duty Clause (GDC) of the RMP expands the analyses to all hazardous substances with potential for offsite consequences. RMP applies to numerous existing and proposed semiconductor manufacturing processes. The RMP process begins with creation of a facility-wide chemical inventory. All applicable processes and other processes with potential off-site impacts then undergo toxicological consequence analysis of off-site health effects from catastrophic release using dispersion modeling. An off-site consequences analysis identifies the hazard or impact zone which is defined as the circular area centered at the point of the release where modeled impacts exceed the toxic or flammable endpoint. For each process, the impact zone and locations of human and sensitive environmental receptors are plotted. These plots are used to make consequences based risk management decisions regarding the types, concentrations and quantities of chemicals used; handling, distribution and release notification and response procedures and systems; and the location of storage relative to offsite and onsite receptors. The potential for adverse public relations related to the perception of poor risk management also enters into these decisions. For future bulk toxic and flammable chemicals systems in the semiconductor industry, an RMP analysis should be performed prior to installation.