Proposed Changes to EPA’s RMP Rule
The US Environmental Protection Agency (EPA) published its long-awaited proposed revisions to the Risk Management Program (RMP) rule (40 CFR 68) in the Federal Register (Vol. 81, No. 49) on March 14, 2016. The proposed revisions include several changes to the accident prevention program requirements, including:
- Changes to some key regulatory definitions
- A requirement for Safer Technology Alternatives Analysis in the process hazard analysis (PHA) for certain Program 3 processes
- Enhancements to the emergency preparedness requirements involving field and tabletop exercises
- Conduct of root cause analyses using a recognized method during incident investigations
- Use of competent, impartial and independent third parties to conduct/submit compliance audits
- Increased public availability of chemical hazard information, including holding public meetings after accidents
- Changes to RMP data elements and submission
A public hearing was held on March 29, 2016 and written comments are due by May 13, 2016 to the RMP rule docket [EPA–HQ–OEM–2015–0725; FRL–9940–94–OLEM].
ABS Group has developed a webinar series that will address important aspects of the proposed revisions, summarize aspects of the Small Business Review and summarize testimony from the public meeting. Potential impacts to industry will be addressed.
Thursday, April 14, 2016: Potential Impacts of EPA Proposed RMP Rule Changes on the Pharmaceutical Industry
Tuesday, April 19, 2016: Proposed Changes to EPA's RMP Rule – Potential Impacts to Industry and How to Get Ready
Steve Arendt is Vice President, Oil, Gas and Chemical for ABS Group. With more than 30 years of experience in chemical process safety and risk management, he has performed hundreds of process safety and security analyses, risk assessments, audits and accident investigations on a variety of oil, gas, chemical and related industry processes.