Bryan Haywood

OSHA, PSM, “Retail”, and LOI’s

It amazes me how society, specifically lawyers and politicians, can be so collectively ignorant.  With all the change in the political winds some industries are breathing a sigh of relief regarding OSHA’s efforts to redefine “retail” when it comes to the “retail exemption” found in their Process Safety Management (PSM) Standard.  For the record, I did

UPDATE: Final Amendments to the Risk Management Program (RMP) Rule

EPA received a petition dated February 28, 2017, from the RMP Coalition, representing several trade associations. The petition requests a reconsideration and request for stay for the RMP rule amendments, published January 13, 2017.   On March 13, 2017, EPA’s Administrator convened a proceeding for reconsideration of the RMP rule amendments.   On March 16,

EPA Extends Comment Period on Risk Management Plan Rule

U.S. Environmental Protection Agency (EPA) Administrator Pruitt took action today to reconsider the “Accidental Release Prevention Requirements: ‘Risk Management Programs Under the Clean Air’” (“RMP Rule”) and signed an administrative stay to DELAY the effective date of the rule regarding chemical accident preparedness and prevention, until June 19, 2017.  The 90-day extension will allow time

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