On July 31, 2014, the USEPA published a Request for Information (RFI) to seek comments on potential revisions to its Risk Management Program (RMP) regulations.

See: http://www.epa.gov/emergencies/eo_improving_chem_fac.htm.

Also see Executive Order (EO) 13650: Improving Chemical Facility Safety and Security. The EO is intended to enhance safety and security at chemical facilities and reduce the risks to all potential affected parties (workers, public, etc.) associated with a hazardous chemical release.

RMP (Section 112[r] of the Clean Air Act) was created in the 1990’s in response to deadly accidental chemical releases in Bhopal, India and Institute, WV. The goal of RMP was to prevent major chemical accidents from causing disasters by establishing a prevention and response program. All facilities that store or use a regulated chemical at or above threshold levels are regulated under RMP. Now that over 20 years have passed since its original inception, the Presidential EO asks whether the program needs to be upgraded, particularly to meet new security (9/11) concerns since its origination.

EO 13650 requires the USEPA and OSHA to review the chemical hazards covered by their existing risk management programs and develop options to improve them. OSHA issued an RFI on potential changes to its Process Safety Management (PSM) standard on December 9, 2013. The USEPA’s recent RFI coordinates with the potential changes to OSHA’s PSM program for accident prevention measures.

The USEPA is considering potentially updating the list of RMP-regulated substances, and adjusting their threshold quantities and toxic endpoints based on up-to-date toxicity research. The RFI seeks comment on potentially changing several existing process safety procedures under RMP including compliance audits; equipment maintenance; management of change; emergency response capabilities; and incident investigation. It also seeks comments on potential additional risk requirements, such as mandatory use of safer technologies; process safety metrics; automated monitoring of releases; emergency drills; stop work authority; and siting risks.
Public comments and other submittals for the RFI, EPA–HQ–OEM–2014–0328, are due on October 29, 2014. They may be submitted by mail or online: www.regulations.gov.

CCES can help your facility determine compliance with the current RMP rule, assist in making your compliance program more streamlined and effective, and in assessing the effects of any future changes to the program to your facility for effective planning. In addition, we can help you assess all of your potential air emissions, as well. Contact us today with any questions at 914-584-6720 or at karell@CCESworld.com.