The U.S. Environmental Protection Agency’s (EPA) small business review panel is seeking comments on proposed changes being considered by EPA on their Risk Management Program (RMP) Rule (40CFR68). Chemical warehouses have been identified as facilities which could be impacted by these changes.

Changes include:

• Third-party compliance audits rather than the current self-audit required by owners.
• In near miss situations, facilities must conduct a root cause analysis (identifying the fundamental reason behind the incident) in addition to the incident investigation.
• Facilities will have to consider a safe alternatives analysis as part of their Process Hazard Analysis to identify safer technologies.
• Facilities are instructed to coordinate with local emergency planning committees and responders on an annual basis and share the facility emergency response program.
• Conduct an annual emergency response notification exercise and field exercise every five years with documentation of those events.
• Increased transparency of RMP information for facilities at various levels: full disclosure of all RMP history for emergency responders, public information is in an easily read format and available every five years or within 30 days of an accident during a public meeting.

Please send your thoughts to IWLA Chemical Council chairman John Auger by Oct. 4. Please view the EPA presentation outlining the changes above.