PT Notes

EPA RMP Rule Amendments - Summary

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 a summary of the U.S. Environmental Protection Agency’s (EPA’s) finalized amendments to its Risk Management Program (RMP) regulation under the Clean Air Act, Section 112(r)(7). The amendments aim to modernize EPA's RMP regulations as required under Executive Order 13650. These amendments seek to 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 principal amendments include:

• Clarification that compliance audits are required for each Program 2 and Program 3 process.
• Third-party audits are required for Program 2 and Program 3 processes under some circumstances.
• An analysis of safer technology and alternatives must be performed as part of the process hazard analysis for some Program 3 processes.
• An incident investigation root cause analysis must be performed for Program 2 and Program 3 processes and other changes have been made to the incident investigation requirements.
• Enhancements to the emergency preparedness requirements have been made.
• Increased public availability of chemical hazard information is required.
• Changes to certain regulatory definitions and data elements submitted in risk management plans have been made.

The final rule was published in the Federal Register on January 13, 2017 with an effective of March 14, 2017. However, the fate of the amendments under the new administration is not clear.

Further PT Notes will provide details on the amendments.

The final rule may be found at:

40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Final Rule

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