Final Rule Alert: EPA Updates Risk Management Program for Chemical Facilities
On December 21, EPA Administrator Gina McCarthy signed a Final Rule to amend the Clean Air Act Risk Management Plan (RMP) requirements for chemical facilities.
Clean Air Act RMP Accident Prevention Program RevisionsThe Final Rule includes three revisions to the accident prevention program requirements under the RMP:
1. Require all facilities with Program 2 or 3 processes to conduct a root cause analysis as part of an incident investigation into a catastrophic release or a near-miss;
2. Require regulated facilities with a Program 2 or 3 processes to contract with an independent third party to perform a compliance audit after the facility has a reportable release; and
3. Require owners or operators of facilities with Program 3 processes under NAICS Codes 322 (paper manufacturing), 234 (petroleum and coal products manufacturing) and 325 (chemical manufacturing) to add a safer technology and alternatives analysis (STAA) to its process hazard analysis (PHA).
A pre-publication copy of the Final Rule is available here.
Clean Air Act RMP Emergency Response “Enhancements”The Final Rule includes three “enhancements” to bolster the requirements for RMP emergency preparedness and response. The RMP emergency response enhancements are as follows:
1. Require owners/operators of facilities with Program 2 or 3 processes to coordinate with local emergency response agencies at least once per year to ensure preparedness to respond to an accidental release of a regulated substance;
2. Require facilities with Program 2 or 3 processes to conduct annual notification exercises to ensure emergency contact information is accurate and complete;
3. Require all facilities subject to the emergency response pre-program requirements (Subpart E) to conduct a full field exercise at least once every ten years and tabletop exercises at least once every three years.
Enhanced Clean Air Act RMP Information AvailabilityLastly, the Final Rule sets requirements to make chemical hazard information more easily available to the public. Among these enhancements is a requirement for the facility owner or operator to provide ongoing notification of information availability on a company website, social media, or other publicly accessible place. If and when an RMP reportable accident occurs, the facility must hold a public meeting within 90 days of the incident.
In the proposed rule, published in the Federal Register in March 2016, EPA put forth requirements for facilities to provide certain information to emergency responders. In the Final Rule, EPA instead will require facilities to share information during annual coordination activities between the facility and responders.
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