EPA Risk Management Plan (40 CFR Part 68) revisions being considered

Here is an inside look at what EPA is considering in their revisions of their Risk Management Plan (RMP) rule.  These items are ONLY being CONSIDERED and DISCUSSED and are in NO WAY concrete changes that have been agreed upon.  Here are the six KEY areas currently in discussion:

1. Third-party audits (applies to the next scheduled audit after an accident)*
2. Incident Root Cause Analysis (only for facilities with accidents/near misses)*
3. Safer Alternatives Analysis (applies to a subset of Program 3 in certain NAICS codes)*
4. Coordinating Emergency Response Program Requirements with Local Responders
5. Emergency Response Exercises for Program 2 and 3 processes*
6. Information Sharing for all program levels*

*New Proposed Requirement