On March 12, 2025, the U.S. Environmental Protection Agency (“EPA”) announced its deregulatory agenda.[1] Although most of the 31 actions identified by the EPA will require formal notice and comment rulemaking, with litigation ensuing, Wednesday’s announcement makes good on the Trump Administration’s promises to roll back environmental regulation.[2]
Of particular significance to the
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,
Although the two programs have significant overlap, each has its own focus. PSM is an occupational health program intended to protect workers; RMP is intended to protect the environment and the community. PSM is an OSHA program, whereas RMP is an EPA program.
Another big difference is that RMP (the program) requires development of a