American Coatings Association


While Section 6(C) of the EO does not specifically direct EPA to release a Request for Information (RFI) on RMP modernization, it directs EPA and OSHA to develop a plan, including a timeline and resource requirements, to expand, implement, and enforce the Risk Management Plan (RMP) and Process Safety Management (PSM) in a manner that addresses the additional regulated substances and types of hazards. Because OSHA released its RFI on PSM modernization, and there is much overlap between PSM and RMP policies, EPA decided to release its own RFI on RMP modernization on July 31, 2014. The RFI includes over 380 questions on a variety of topics, including topics that directly overlap with OSHA’s PSM questions. Many of the proposed changes to RMP regulations could potentially increase costs and increase the number of regulated sources, such as 1) mandatory third party compliance audits, 2) mandatory installation of automated detection and monitoring systems, 3) requiring covered sources to install emergency shutdown systems, 4) amending the list of regulated substances to add more toxic or flammable substances, high or low explosives, or reactive hazards, 5) requiring an analysis and documentation of inherently safer technologies (ISTs) and alternatives, 6) creating additional stationary source location requirements (ie. creating buffer zones), 7) identifying ways to make regulated facilities publish more facility information without creating security concerns, and 8) adopting the UK’s “Safety Case” regulatory model as an alternative to RPM and PSM.

 

Resources

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For more information:

Rhett Cash
Counsel
202-719-3680

 

Xavier Ferrier
Specialist, Environmental Health & Safety
202-729-3911


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