On June 9, 2017, the United States Environmental Protection Agency (EPA) administrator signed a final rule to further delay the effective date of the Risk Management Program (RMP) rule amendments for 20 months until February 19, 2019.
The rulemaking was initiated as a part of President Obama’s Executive Order on Improving Chemical Facility Safety and Security, which came in response to the fertilizer plant explosion in West, Texas, in 2013. GCCA played an active role engaging with EPA on its proposed revisions to RMP and led an industry coalition expressing concerns with several of EPA’s proposals along the way. Continue reading
On March 29, 2017, The United States Environmental Protection Agency (EPA) Administrator Scott Pruitt signed a proposed rule to further delay the effective date of the Risk Management Program (RMP) rule that was finalized at the end of the Obama Administration. The proposed rule postpones the effective date until February 19, 2019. This action will allow EPA to consider several petitions for reconsideration of the RMP rule amendments and take further regulatory action. EPA will hold a public hearing on April 19th regarding the proposed new effective date. GCCA is planning to participate in the public hearing to express support for the delay and highlight concerns with the RMP Final Rule as it is currently drafted.
United States Environmental Protection Agency (EPA) Administrator E. Scott Pruitt has signed a 90 day delay of the Risk Management Program (RMP) rule effective date. This is an important step for the new Trump Administration’s EPA to review the Final Rule and determine any future actions. The Global Cold Chain Alliance (GCCA) supports the delay and is part of the RMP Coalition that submitted the petition referenced in the EPA order linked here. Continue reading
On March 29th, the Environmental Protection Agency (EPA) held a public meeting to receive comments on its recently released proposed rule to amend the Risk Management Program (RMP) regulations. Lowell Randel, GCCA Vice President of Government and Legal Affairs, spoke to EPA officials regarding the cold chain industry’s concerns with the EPA proposals. His comments focused on the proposed requirements for facilities to conduct a third party audit after an RMP reportable accident. Randel stated that the current practice of allowing flexibility to use in house personnel to conduct audits should remain in place. He also expressed strong concerns that the proposed independence requirements of third party auditors are overly restrictive would lead to a shortage of qualified auditors with experience in industrial refrigeration facilities. He also addressed other concerns related to the definition of “near miss” triggering a root cause analysis and the proposed requirement to conduct a public meeting within 30 days of an accident. GCCA will be working with coalition partners to develop more detailed written comments. More information on the EPA’s proposed rule can be found here.
On February 25th, the Environmental Protection Agency (EPA) issued its pre-publication version of a proposed rule to modernize the Risk Management Program. Once published in the Federal Register, the public will have 60 days to provide comment. A copy of the proposed rule can be found here.
EPA is proposing changes to RMP in the following areas (a summary of each issue is provided at the end of this post):
· Root Cause Analysis
· Independent Third Party Audits
· Inherently Safer Technology Assessments
· Emergency Response Enhancements
GCCA participated in a small business review panel that EPA convened in preparation for the RMP proposed rule. During this process, GCCA expressed its concerns with many of the provisions that have been included in the proposed rule. A copy of GCCA’s comments to EPA is attached to this post. GCCA will continue to lead a coalition to respond to the proposed rule and communicate the industry’s concerns. Continue reading