What does EPA’s RMP “General Duty Clause” actually require?

Almost weekly I see and hear the RMP “General Duty Clause” (GDC) being misquoted and improperly applied.  In this article I hope to clarify many of the myths and misconceptions of what EPA actually requires in the application of their GDC’s to RMP chemicals.  First and foremost, there is NO GET OUT OF JAIL FREE...

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