On June, 9, 2017, Scott Pruitt signed a final rule delaying the effective date of the RMP rule until February 19, 2019. The Environmental Protection Agency” (“EPA”) stated that it had received 54,117 public comments, 54,000 of which were part of a mass mail campaign, leaving 108 submissions with unique content. A final rule is
RMP Rule
EPA Proposes to Further Delay Effective Date of RMP to 2019
By Kean Miller on
The EPA received three petitions asking it to delay and reconsider amendments to the RMP rule. First, the “RMP Coalition” submitted a petition dated February 28, 2017. On March 13, 2017, the Chemical Safety Advocacy Group also submitted a petition, followed by a third petition from a group of eleven states. On March 13, 2017,…
EPA Delays Effective Date of RMP
By Kean Miller on
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:…
EPA RMP Requirements: Emergency Response Preparedness Requirements
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 a fifth in a planned series that will address five major changes: root cause analysis for near misses, third-party audits, inherently…
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: 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,…