Tag: Risk Management Program

Will RMP and PSM Revisions Create More Overlap?

EPA’s Chemical Accident Prevention Program, more commonly referred to as the Risk Management Program (RMP), and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) program will always go hand in hand, as both seek to prevent chemical process accidents and protect workers and the public from the sometimes devastating consequences of such […]

Will RMP and PSM Revisions Create More Overlap?

EPA’s Chemical Accident Prevention Program, more commonly referred to as the Risk Management Program (RMP), and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) program will always go hand in hand, as both seek to prevent chemical process accidents and protect workers and the public from the sometimes devastating consequences of such […]

Opposite Camps Fault RMP Proposal

In its spring 2016 regulatory agenda, the EPA set a December 2016 completion date for its final revisions of regulations implementing Clean Air Act (CAA) Section 112(r), the Risk Management Program (RMP). Since issuing the first RMP rule in 1996, the Agency has revised the requirements at least six times. But the most recent proposed […]

Webinar Wrap-Up: RMP Updates

Back in March, the U.S. Environmental Protection Agency (EPA) proposed significant changes to the chemical accident prevention provisions, commonly referred to as the Risk Management Program (RMP). In a recent webinar, Risk Management Plan Updates: A Guide to Regulatory Compliance in Advance of EPA’s Final Rule, speaker Natalie VanLiew, PE, Managing Consultant at Trinity Consultants, […]

EPA Releases Proposed Changes to the Cost of RMP

The U.S. Environmental Protection Agency (EPA) recently released its proposed amendments to the Chemical Accidental Release Prevention Program, aka the Risk Management Program. Concurrently, the Agency also released a Regulatory Impact Analysis (RIA). Yesterday we reviewed EPA’s estimated costs for changes concerning third-party audits, root cost analyses, and safer technology and alternative analyses. Today we […]

How Much You Say? What EPA Claims Changes to RMP Will Cost

The U.S. Environmental Protection Agency (EPA) recently released its proposed amendments to the Chemical Accidental Release Prevention Program, aka the Risk Management Program. Concurrently, the Agency also released a Regulatory Impact Analysis (RIA). Today and tomorrow, we will explore how much the EPA says the major changes will cost. After comments flow into the Agency, […]

How to Avoid RMP

Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]

RMP under Scrutiny

The EPA recently issued an updated request for information (RFI) seeking public comment on updating its Risk Management Program regulations, and a notice of proposed rulemaking is being prepared.  In the original RFI, the Agency noted that it is looking for specific feedback on whether the list of Risk Management Program (RMP)-regulated substances should be […]

RMP—No Release but a Huge Fine Anyway

It’s hard to swallow a huge fine for what might have happened. But, as part of its efforts to comply with the president’s EO to improve safety and security at chemical facilities, the EPA is hunting down companies that are required to develop RMPs but have not even though there has not been a release […]