PT Notes

Proposed Amendments to EPA's RMP Regulation

PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.

This PT Note provides an overview of the U.S. Environmental Protection Agency’s (EPA’s) proposed amendments to its Risk Management Program (RMP) regulation in response to Executive Order 13650.

EPA intends that the proposed amendments will improve chemical process safety, assist local emergency authorities in planning for and responding to accidents, and improve public awareness of chemical hazards at regulated sources.

The proposed amendments include:

• Changes to the accident prevention program requirements:
  • Incident investigation root cause analysis for Program 2 and Program 3 processes.
  • Third-party audits for facilities with Program 2 or 3 processes after an accident or findings of significant non-compliance by an implementing agency.
  • Analysis of safer technology and alternatives as part of the process hazard analysis for some Program 3 processes to evaluate the feasibility of any inherently safer technology identified.
• Enhancements to the emergency preparedness and response requirements.
• Improvements to the public availability of chemical hazard information.
• Several other changes to certain regulatory definitions and data elements submitted in risk management plans.

Further details can be found at:

https://www.regulations.gov/#!documentDetail;D=EPA-HQ-OEM-2015-0725-0001

Future PTNotes will provide details on each of the proposed amendments.

EPA is soliciting comments on the proposed amendments which must be submitted on or beforeMay 13, 2016. Comments should be identified by docket EPA-HQ-OEM-2015-0725 and submitted through the Federal eRulemaking Portal: http://www.regulations.gov.

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