What Changes to EPA's Risk Management Program will Mean to Affected Industry and Surrounding Communities

摘要

In March 2016 U.S. EPA proposed changes to the Risk Management Program (RMP) and associated guidance in response to the Executive Order 13650 - Improving Chemical Facility Safety and Security. Presently there are about 12,000 facilities across the United States that are subject to RMP and the revised regulations may result in adding facilities to this program. EPA promulgated revisions to RMP (40 CFR Part 68) on January 13, 2017. These changes potentially affect how regulated processes will need to be designed and operated and what elements new elements will need to be added to existing risk management programs. This paper reviews the promulgated changes to RMP elements and implications for currently regulated industries. The paper also examines how changes could materially enhance public safety by improving accident prevention and emergency preparedness. Among the elements to be reviewed are requirements for consideration of inherently safer technologies as part of the process hazards assessment, third party audits, public meetings to discuss reported incidents and enhanced emergency response requirements.