On February 28, 2017, the EPA received a petition from the “RMP Coalition” for reconsideration and a request for a stay from the amendments to the RMP rule. The RMP Coalition consists of several affected industry trade groups, manufacturing groups, and the Chamber of Commerce of the United States of America. The petition asserts that:
OSHA
EPA RMP Requirements: Information Availability
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule . On January 13, 2017, the EPA published a new final rule. This is the final article in a series that addresses five major changes: root cause analysis for near misses, third-party audits, inherently safer technology,…
EPA RMP Requirements: Emergency Response Preparedness Requirements
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule . On January 13, 2017, the EPA published a new final rule. This a fifth in a planned series that will address five major changes: root cause analysis for near misses, third-party audits, inherently…
Petroleum Refineries are back in OSHA’s National Emphasis Program (NEP) – New NEP to Apply to All
Effective January 17, 2017, the Occupational Safety and Health Administration (OSHA) issued new instructions concerning its National Emphasis Program (NEP) as it relates to chemical process subject to Process Safety Management (PSM). See Directive Number CPL-03-00-021. PSM requirements are codified at 29 CFR 1910.119. Prior NEPs were implemented for Petroleum Refining in 2007 and…
EPA RMP Requirements: Safer Technology and Alternatives Analysis
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule. On January 13, 2017, the EPA published a new final rule. This is fourth in a planned series that will address five major changes: root cause analysis for near misses, third-party audits, inherently safer technology,…
EPA RMP Requirements: Third Party Audits Criteria and Implementation of Findings
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule. On January 13, 2017, the EPA published a new final rule. This is third in a planned series that will address five major changes: root cause analysis for near misses, third-party audits, inherently safer technology,…
EPA RMP Requirements: Third Party Audits and Privilege
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule. On January 13, 2017, the EPA published a new final rule. This a second in a planned series that will address five major changes: root cause analysis for near misses, third-party audits, inherently safer technology,…
OSHA Updates Safety Rules for Walking-Working Surfaces
On November 18, 2016, the Occupational Safety and Health Administration (“OSHA”) issued a final rule “revising and updating its general industry standards on walking-working surfaces to prevent and reduce workplace slips, trips, and falls, as well as other injuries and fatalities associated with walking-working surface hazards.” 81 Fed. Reg. 82494 (Nov. 18, 2016) . Regulations…
Modified OSHA Policy Statement Defining Applicability: The “One Percent Rule” and Aqueous Mixtures
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
OSHA Announces Final Rule Making Information on Workplace Injuries and Illnesses Available Online
Today, the Occupational Safety and Health Administration (“OSHA”) announced a final rule that will make information regarding workplace injuries and illnesses available online. OSHA already requires many employers to keep a record of injuries and illnesses, but little or no information about worker injuries and illnesses at individual employers is made public. The new regulation…