Regulatory Update — EPA Issues Request for Comments on Risk Management Program Expansion


Last week, the U.S. Environmental Protection Agency (EPA) published a Request for Information (RFI) to seek comment on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations as required under Executive Order (EO) 13650: Improving Chemical Facility Safety and Security.

The EPA specifically requests input on updating the list of RMP-regulated substances and adjusting threshold quantities and toxic endpoints based on Acute Exposure Guideline Level toxicity values; and on strengthening or clarifying several existing process safety elements under the RMP, including compliance audits, maintenance of safety critical equipment, managing organizational changes, emergency response capabilities, and incident investigation. The agency also seeks comment on adding additional risk management program elements, such as consideration of using inherently safer technology, process safety metrics, automated monitoring of releases, emergency drills, stop work authority, and addressing facility location (siting) risks.

The EPA says the information received will be used when reviewing chemical hazards covered by the RMP and to determine how this program should be expanded to improve chemical facility safety. NACD's Regulatory Affairs Committee and Environmental/Safety/Process Safety Subcommittee will carefully review the RFI and submit comments to the EPA.

If you have comments or would like to be involved in this effort, please contact NACD Vice President of Regulatory Affairs Jennifer Gibson at jgibson@nacd.com. Click here to view the pre-Federal Register publication version of the RFI. Once the notice is officially published, interested parties will have 90 days to comment.

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