On March 2, 2017, the EPA withdrew its information collection request (ICR) regarding methane emissions from existing oil and gas facilities. EPA finalized and issued the underlying ICR on November 10, 2016. Since that time, EPA sent letters to thousands of owners and operators in the oil and gas industry, requiring them to complete surveys
EPA RMP Requirements: Safer Technology and Alternatives Analysis
By Kean Miller on
Posted in OSHA, Process Safety Management
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
By Kean Miller on
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,…
EPA RMP Requirements: Root Cause Analysis for Near Misses
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the Risk Management Plan Program (“RMP”) Rule. On December 21, 2016, the EPA disclosed its changes via a Pre-Publication Copy. A series of blogs are planned to address five major changes: root cause analysis for near misses, third-party audits, inherently safer technology,…
EPA Amends the Risk Management Program (RMP) Rule
By Kean Miller on
On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the RMP Rule . On December 21, 2016, the EPA disclosed its changes via a Pre-Publication Copy.
In the proposed rule, the EPA essentially agreed that the scope and trigger for post incident investigation was not universally understood or applied. The final rule…
Modified OSHA Policy Statement Defining Applicability: The “One Percent Rule” and Aqueous Mixtures
By Kean Miller on
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…
EPA Recognizes that the Baton Rouge Area Attained the 2008 8-Hour Ozone Standard
By Kean Miller on
The May 4, 2016, Federal Register contains a notice of the Environmental Protection Agency’s (“EPA’s”) final decision that the Baton Rouge ozone nonattainment area has attained the 2008 8-hour ozone National Ambient Air Quality Standard (“NAAQS”). 81 Fed. Reg. 26,697. (The Baton Rouge nonattainment area consists of the parishes of Ascension, East Baton Rouge, Iberville,…
EPA Poised to Begin Collecting Methane Data from Existing Oil & Gas Facilities
By Kean Miller on
The Environmental Protection Agency (EPA) announced in March that it is in the process of developing new regulations to curb methane emissions from existing oil and gas facilities. The EPA will formally require companies operating existing oil and gas sources to provide information to assist in the development of comprehensive regulations to reduce methane emissions. …
EPA’s Proposed Revisions to RMP Rules have Arrived
By Kean Miller on
The Environmental Protection Agency (“EPA”) published a Request for Information (“RFI”) on July 31, 2014 relating to possible changes to the Risk Management Program (“RMP”) rules codified at 40 C.F.R. Part 68. See 79 Fed. Reg. 44604 (July 31, 2014). On June 19, 2015, OSHA, the EPA, and the Department of Homeland Security held a…