Risk Management Plan Requirements Delayed

In January 2017, EPA published amendments to the Risk Management Program (RMP) Rule 40 CFR Part 68. The amendments included requirements for:

• Root cause analysis as part of an incident investigation;
• Independent third-party compliance audits following a release event reportable under RMP or when an agency requires it based on site conditions;
• Inclusion of a safer technology and alternatives analysis as part of the process hazard analysis for processes in North American Industry Classification System (NAICS) codes 322, 324, and 325 (manufacturing of Paper, Petroleum and Coal Products, and Chemicals);
• Emergency response enhancements such as annual coordination with local emergency response agencies, annual testing of emergency notification procedures, and full field exercises at least every 10 years for responding facilities; and
• Measures to increase availability of chemical hazard information to the public.

Aboveground Product Vessels



Following publication of the amendments, EPA received several petitions for reconsideration and request for stay of the amendments. On June 9, 2017, the EPA Administrator signed a final rule to delay the effective date of the RMP rule amendments until February 19, 2019.





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