ACC Comments: EPA’s New RMP Rule Raises Concerns

AcuTech has evaluated the potential impacts of the EPA’s published final rule via our whitepaper and a webinar series. While the final rule is published, it is important to keep up to date with ongoing discussions which may impact the rule in the future. Please see recent commentary on the EPA RMP rule via ACC:

ACC Comments on House Hearing Examining Changes to Chemical Safety Program

Recent AcuTech Analysis of the EPA RMP Rule

AcuTech recognizes the significance of the new rule in the industry, dedicating the past two months to hosting webinars and crafting a white paper on its implications for regulated facilities. The first two sessions of the webinar series provided an overview of the changes and delved into the safer technologies and alternatives analysis requirement.

The accompanying white paper summarizes key points essential for industry compliance planning, covering enhanced enforcement, hazards analysis, third-party audits, and emergency response planning.

This final webinar will be a deeper dive into audits, facility siting, and emergency response. Join us to hear insights on the new requirements, what potential challenges might arise, and how to address them.

2024 Revisions to the EPA’s Risk Management Program (RMP) Rule:
Audits, Facility Siting, and Emergency Response

Wednesday, June 3, 2024
12:00 – 1:00 PM EDT

Discover the latest updates to the EPA’s RMP rule and its enforcement, including the following:

  • Third Party Audits: The requirement for some sites to use third-party auditors for the tri-annual compliance audit may result in new and unexpected opinions on compliance that will need to be managed, especially for those sites where self-auditing was the norm, particularly the accommodation of dissenting opinions among auditors.
  • Stationary Source Siting: The hazard evaluations conducted the PHA element explicitly define stationary source siting as inclusive of the placement of processes, equipment, buildings within the facility, and hazards posed by proximate facilities, and accidental release consequences posed by proximity to the public and public receptors.  EPA did not define the analytical methods or techniques to be used to determine the consequences.
  • Emergency Response Activity: Greater emphasis on emergency response planning and coordination with first responders.

Final Rule

The final rule is on the EPA’s Risk Management Program rule website. Read the final rule.

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