Practical EHS Tips, News & Advice. Updated Daily.
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, […]
Q. Would the risk management plan (RMP) flammable substance exemption include warehouses? We will store cans of foam containing isobutane. Will the RMP regulations apply?
The U.S. Environmental Protection Agency (EPA) proposed what it calls the Hazardous Waste Generator Improvements on September 25, 2015. An extended comment period closed December 24, 2015. The Agency has received over 230 comments on the proposal. The Advisor reviewed a number of them and will give you the gist of what people are saying […]
As discussed in yesterday’s Advisor, thousands of retail facilities face stricter requirements under the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) because of a controversial Occupational Safety and Health Administration (OSHA) interpretation of a retail exemption under the Process Safety Management (PSM) standard. Here’s how to get started in RMP Program Level 3. Beginning […]
Thousands of retail facilities face stricter requirements under the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) because of a controversial Occupational Safety and Health Administration (OSHA) interpretation of an exemption under the Process Safety Management (PSM) standard. Today we will review EPA’s reaction to OSHA’s narrowing of the retail exemption. Beginning in July 2016, […]
The U.S. Environmental Protection Agency (EPA) has been under pressure to update and better manage its Clean Air Act Risk Management Program and is moving ever closer to a proposed rule that will modify the program. The Agency continues to scrutinize facilities that are required to have risk management plans. Today we will review a […]
For employers that handle small quantities of highly hazardous chemicals or large quantities of flammable liquids or gases, the Occupational Safety and Health Administration’s (OSHA) process safety management (PSM) standard (29 CFR 1910.119) imposes extensive requirements on the handling of those substances. Until July 2015, many employers were avoiding the need to comply with those […]
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 […]
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 […]
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 […]