EPA Proposes Changes to Chemical Risk Management Program (RMP)

Posted on 2/29/2016 by Roger Marks

Update 03/14/16: EPA's proposed changes to the Risk Management Program (RMP) appeared in the Federal Regsiter today.
US EPA has proposed revisions to its Risk Management Program (RMP) for facilities that manufacture, use, or store certain thresholds of hazardous chemicals. RMP came into being with the passage of the Clean Air Act Amendments of 1990, which required US EPA (and OSHA) to develop regulations and guidance for preventing large-scale chemical accidents. OSHA, for its part, created its Process Safety Management (PSM) requirements, which are similar—but not quite identical—to EPA’s RMP rules.

In a press release dated February 25, EPA states that more than 1,500 accidents have occurred at facilities covered by the RMP standards in the last 10 years, responsible sixty deaths, 17,000 injuries or illnesses, and half a million people being evacuated or sheltered-in-place. On top of the human cost, these chemical accidents resulted in $2 billion in property damage.

According to EPA’s new RMP proposal, a disproportionate share of reportable chemical releases stem from three industries: paper manufacturing, petroleum and coal products manufacturing, and chemical manufacturing.

EPA estimates that the proposed rule will affect more than 12,500 RMP-covered facilities.

Proposed RMP Revisions

Among the changes for RMP covered facilities:

  • Changes to the accident prevention program requirements, including additional analyses of safer technology and alternatives for the process hazard analysis for some Program 3 processes
  • “Enhancements” to the emergency preparedness requirements
  • More public availability of chemical hazard information
  • Other changes to definitions and data elements required under the RMP

Who’s covered by the Risk Management Program (RMP)?

Clean Air Act Risk management audit

Changes to the RMP Accident Prevention Program

The proposed 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).
Emergency Response “Enhancements”

  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 preprogram requirements (Subpart E) to conduct a full field exercise at least once every five years and one table top exercises annually in other years; and  
  4. Require facilities with an RMP reportable accident to conduct a full field exercise within one year of the accident.

Enhanced Availability of RMP Information

To make more information available to the communities where manufacturing activities may expose the public to hazardous chemicals, EPA’s proposal would require all facilities to provide certain basic information to the public in a way that’s easy to access, like a website, or at a public library or government office.

The proposal includes requirements for certain facilities to provide information to their Local Emergency Planning Committee (LEPC), Tribal Emergency Planning Committee (TEPC), or other emergency planning group: 

  1. Facilities with Program 2 and 3 processes would be required to provide summaries of their compliance audit activities and emergency response exercises.
  2. Facilities running some Program 3 processes must provide information about any inherently safer technologies (ISTs) implemented at the facility.
  3. Any facility at which an RMP reportable accident occurs would be required to hold a public meeting for the local community within a specific timeframe following the accident.   
A pre-publication draft of the proposed changes to the Risk Management Program is available here.

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Tags: Act, Air, Clean, EPA, new rules, RMP

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