The Environmental Protection Agency recently posted proposed changes to the Risk Management Program regulations.
The Agricultural Retailers Association is in the process of reviewing the complex, nearly 250-page document. As spring is a busy time for agricultural retailers, ARA will likely ask EPA to extend the comment period so our members have sufficient time to review and assess the impact of EPA's proposed rule changes.
ARA had several members participate on the EPA RMP Small Business Entity Panel who raised key concerns with the agency's initial proposal. ARA plans to fully review this proposal and provide comments to the agency before the deadline. We will also work with national and state allied organizations on a coordinated message to EPA and Congress.
According to EPA, the proposed amendments are intended to improve existing risk management plan requirements to enhance chemical safety at RMP facilities by:
- Requiring the consideration of safer technologies and alternatives by including the assessment of Inherently Safer Technologies and Designs in the Process Hazard Assessment;
- Requiring third party audits and root cause analysis to identify process safety improvements for accident prevention;
- Enhancing emergency planning and preparedness requirements to help ensure coordination between facilities and local communities;
- Strengthening emergency response planning to help ensure emergency response capabilities are available to mitigate the effect of a chemical accident;
- Improving the ability of LEPCs (Local Emergency Planning Committees) and local emergency response officials to better prepare for emergencies both individually and with one another; and
- Improving access to information to help the public understand the risks at RMP facilities.
Contact Richard Gupton, ARA senior vice president of public policy and counsel (firstname.lastname@example.org), with questions or for more information regarding this issue.