EPA UPDATES their RMP GDC guidance (April 2020)

Under the Clean Air Act Section 112(r)(1), the General Duty Clause states:

“The owners and operators of stationary sources producing, processing, handling or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the general duty clause in the Occupational Safety and Health Act (OSHA)] to identify hazards which may result from (such) releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”

WHAT IS THE GENERAL DUTY CLAUSE?

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