This week (2/24/16) we saw the Office of Management and Budget approve EPA’s Notice of Public Rule Making (NPRM) in their attempt to revise their Risk Management Plan rule. Several weeks ago I posted some of the revisions that EPA is considering and it is hard not to argue for all of their proposed revisions – maybe some of the details can be debated – but the elements they are focused on and the scope of their revisions make sense from a process safety perspective.
- Third-party audits (applies to the next scheduled audit after an accident)
- Incident Root Cause Analysis (only for facilities with accidents/near misses)
- Safer Alternatives Analysis (applies to a subset of Program 3 in certain NAICS codes)
- Coordinating Emergency Response Program Requirements with Local Responders
- Emergency Response Exercises for Program 2 and 3 processes
- Information Sharing for all program levels to help the public understand the risks at RMP facilities
CLICK HERE for the official word
I have also been hearing rumors that OSHA is seriously considering letting EPA’s RMP NPRM finish before they move to do their NPRM for their PSM standard and that would be a HUGE delay in many ways for businesses impacted by OSHA’s desire to revise the definition of “retail”, remove the “atmospheric storage tank exemption” and to pull in “oil and gas exploration” into the scope of the standard. Right now its mere rumblings I hear at meetings with folks who are better connected than me, but I am hearing it more and more from very reliable sources so we will just have to wait and see how this all plays out. As soon as EPA posts their revised RMP rule I will be sure to let you know.