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US Regulatory Reforms for Process Safety

Changes to EPA RMP for Chemical Facilities

As a result of perceived poor industry process safety performance over the past decade, and due to recent notable accidents in Texas and California, the U.S. Government issued Executive Order 13650 - Improving Chemical Facility Safety and Security on August 1, 2013. The Executive Order established an OSHA/EPA/DHS Working Group to develop action plans over the next six months to find ways to:

  • Improve operational coordination with states, tribes and local partners
  • Enhance information collection and sharing
  • Modernize regulations, guidance and policies
  • Identify best practices in chemical facility safety and security

Our video linked below explains the proposed changes to Cal/OSHA's Process Safety Management (PSM) Regulation. For more guidance resources, request access to our Cal/OSHA PSM Regulation for Refineries Toolkit.

Improving Chemical Facility Safety and Security

The Request for Information regarding modernizing EPA's Risk Management Plan (RMP) Regulation was published during summer 2014, and comments were received later in the year. Based on that input, on March 14, 2016, EPA published its proposed revisions. These include several changes to the accident prevention program, including:

  • Changes to some key regulatory definitions
  • A requirement for Safer Technology Alternatives Analysis in the 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

What These Changes Mean to Industry

These potential changes could significantly increase the regulatory compliance burden/risk for many chemical, petrochemical, oil and gas, and related industries/facilities for:

  • Plant Siting and Buffer Zones
  • New Projects
  • Existing Plant Upgrades
  • Stakeholder Interactions

Preparing for Changing Regulations

In addition to staying up to date through our dedicated webinar series on this topic, we suggest considering the following points as you prepare for changing regulations: 

  • Continue monitoring now; get active during any future RMP rulemaking and monitor for changes occurring in OSHA PSM changes
  • Begin developing your own positions on what you believe should be done and collect data to support your case
  • Determine your views on PSM/RMP changes that are likely and conceive of smart things to do over the next couple of years to be in a better compliance position

Compliance Management Services

Our subject matter experts were involved with several industry groups during the original PSM and RMP rulemakings and have written many industry PSM/RMP compliance and process safety effective practices guidelines. We have assisted industry and other stakeholders with understanding and determining cost-effective compliance solutions, including leading national PSM/RMP rollout workshops and RMP public communication efforts. Our PSM engineers have the necessary experience and insight to help guide you through these changing regulations, helping your organization stay informed and ahead of compliance.

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