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.
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What you will learn
- 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