Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many of them are four years away.)
While the rule isn’t *official* until it’s published in the Federal Register, they have provided the prepublication version with commentary on their website. The document itself is 372 pages long which is impressive considering the original rule is 17 pages. UPDATE: Federal Register publication link.
Here’s part of what the EPA had to say about changes to the rule:
SUMMARY: The Environmental Protection Agency (EPA), in response to Executive Order 13650, is amending its Risk Management Program regulations. The revisions contain several changes to the accident prevention program requirements including an additional analysis of safer technology and alternatives as part of the process hazard analysis for some Program 3 processes, third-party audits and incident investigation root cause analysis for Program 2 and Program 3 processes; enhancements to the emergency preparedness requirements; increased public availability of chemical hazard information; and several other changes to certain regulatory definitions and data elements submitted in risk management plans. These amendments seek to improve chemical process safety, assist local emergency authorities in planning for and responding to accidents, and improve public awareness of chemical hazards at regulated sources.
I have created a 55 page summary that lists:
- What the new text says.
- What the new text means.
- What you must do (and when you must do it!) to become compliant.
You can download that document in Microsoft Word (so you can make your own personal notes) at this link: 40CFR68 – 2016 Amendments BDC 122116.
Obviously, there are going to be many changes required to your element guidelines and practices. RC&E will be updating our template program to become compliant with the new requirements in the first quarter of 2017 and will make these updated documents available to our clients as they are completed.
Updated link to the EPA documents: Click Here
Link to our summary: 40CFR68 – 2016 Amendments BDC 122116