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,
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,
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