What are the final changes in the Safer Communities by Chemical Accident Prevention (SCCAP) Rule?

Some of the more eye-opening revisions:

1. Outlining STOP-WORK procedures in Program 3 employee participation plans
2. A justification in the risk management plan is required when:
   1. hazard evaluation recommendations are NOT adopted
   2. facility-siting hazard recommendations are NOT adopted
   3. Safer Technology Alternatives Analysis (STAA) recommendations are NOT adopted
   4. third-party compliance audit recommendations are NOT adopted
3.  A formal root cause analysis incident investigation is required when facilities have had an RMP-reportable accident
4. Requiring employee participation in resolving PHAs, CAs, and IIs recommendations and findings
5. Hot work permits should be retained for three years

 Here is a summary of all the new requirements: