NAEM Web Seminars are an easy and cost-effective way to share a learning experience with your colleagues. With one registration you can gather your entire EHS team around a computer or projector screen to collectively participate and brainstorm ideas
Regulatory Changes Ahead: Preparing for PSM and RMP Updates
Thursday November 17, 2016
1:00 -2:00 p.m. (ET)
Cost: FREE for Members, $99 for Non-Members
U.S. EPA has proposed changes to its Risk Management Program (RMP) regulations, while OSHA has issued new clarifying guidance on RMP’s sister regulation, the Process Safety Management (PSM) rule. These changes may affect corporate EHS processes by potentially broadening the applicability of the rules, altering the manner in which compliance with the rule is demonstrated and, in a worst-case scenario, imposing significant design standard requirements on affected equipment.
Although PSM and RMP currently only apply to a limited number of facilities (i.e., those that have more than a threshold amount in a process), both OSHA and the Clean Air Act have "General Duty" clauses that extend the requirements of both rules to otherwise unaffected facilities. A recent USEPA enforcement initiative under the RMP regulation illustrates the seriousness with which the agencies view process safety and risk management as everyone's responsibility.
The presentation will include:
- Overview of the proposed changes to RMP rules and PSM’s implementing guidance
- Discussion of the General Duty clauses under both acts and the link to corporate EHS responsibilities
- Review of USEPA's recent RMP enforcement initiative (centered around anhydrous ammonia systems) and how those results, when viewed through recent case studies, may shape compliance with these regulations
- Matthew Traister, P.E., Vice President & National Compliance Practice Leader; O'Brien & Gere
Matthew Traister, P.E.
Matthew Traister, P.E. is a Vice President with OBG and is the Firm's subject matter expert on air quality. A registered Professional Engineer (chemical) and the head of O'Brien & Gere's National Compliance Practice, Mr. Traister has more than 29 years of environmental consulting experience involving air permitting, emission inventory development, and air and odor pollution control design projects. The author of more than 40 technical papers and publications, Mr. Traister routinely provides project management and technical oversight functions for complex regulatory compliance programs including those under the Clean Air and Clean Water Acts, the Emergency Planning and Community Right-to-Know Act, and the Resource Conservation and Recovery Act (RCRA).