Here We Go Again: EPA's Proposed Changes to the RMP Program
On August 31, 2022, EPA published a proposed rule that would make a number of key changes to the federal Risk Management Plan (RMP) program. The proposed changes would impact the scope of the Process Hazard Analysis (PHA), third-party compliance audits, employee participation requirements, and information sharing with the public and local emergency responders, among other requirements. The proposal would bring back to the program, with some tweaks, a number of changes that EPA had adopted in the final days of the Obama administration that never became effective and were subsequently rescinded as part of a 2018-2019 reconsideration proceeding. The public comment period on the proposed rule ends on October 31, 2022.
Join Bracewell ELR team members Steven Cook and Whit Swift as they discuss key elements of the proposed rule and how the changes, if adopted, will impact companies subject to the RMP program.