PT Notes

EPA RMP Rule 2024 Amendments - Risk Management Plan

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.

EPA has made the following changes to the Risk Management Plan:

Registration

The following requirement is added:

Method of communication and location of the notification that chemical hazard information is available to the public residing, working, or spending significant time within 6 miles of the stationary source, per the rule.

Prevention Program

For Program 2 and Program 3 processes:

The following requirement was added:

Recommendations declined from natural hazard, power loss, and siting hazard evaluations and justifications.

The following text was revised:

The date of the most recent compliance audit; the expected date of completion of any changes resulting from the compliance audit and identification of whether the most recent compliance audit was a third-party audit, and findings declined from third-party compliance audits and justifications.

For Program 3 processes, the following requirements were added:

Inherently safer technology or design measures implemented since the last PHA, if any, and the technology category (substitution, minimization, simplification and/or moderation).

Recommendations declined from safety gaps between codes, standards, or practices to which the process was designed and constructed and the most current version of applicable codes, standards, or practices.

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Disclaimer: This PT Note provides Primatech’s interpretation of regulatory requirements. The actual regulatory requirements can be found at: https://www.epa.gov/rmp

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