Accidental Release Prevention Requirements: RMP Standards Have Significant Changes in 2024

EHS Support understands the importance of staying ahead when it comes to compliance. In March 2024, the United States Environmental Protection Agency (USEPA) announced notable changes to the Risk Management Program (RMP) standards, aimed at enhancing safety and reducing the risk of accidents involving hazardous chemicals. We are providing you with the latest updates on changes to the RMP program and how it can impact your business.

What is RMP?

The RMP standards were established under Section 112(r) of the Clean Air Act to prevent and mitigate chemical accidents at facilities that use certain hazardous chemicals in excess of threshold quantities. These standards require regulated facilities to create and implement a risk management plan to prevent accidents, prepare for emergencies, and lessen the impact of any releases. This standard has historically followed the Occupational Health and Safety Administration (OSHA) General Industry standard for Process Safety Management (PSM) under Code of Federal Regulations (CFR) 29 1910.119.

What are the significant changes to the RMP standards?

These updates that go into effect on May 10, 2024, mark a significant milestone in regulatory efforts to safeguard communities, workers, and the environment from potential hazards posed by chemical facilities. Key changes include:

  1. Enhance Accident Prevention Program (APP): The updated standards now require facilities to enhance their APPs by conducting a root cause analyses for incidents that could have resulted in a catastrophic release. This analysis helps ensure corrective actions are in place to prevent the incidents from happening again.
  2. Undergo Third-Party Compliance Audits: To ensure compliance and accountability, certain facilities covered by the RMP standards must undergo third-party compliance audits every three years. The audits will assess the facility’s compliance with RMP requirements and the effectiveness of its accident prevention program. Under specific circumstances, the audits can no longer be performed “in house.”
  3. Conduct Safer Technologies and Alternatives Analysis (STAA): Facilities are now required to conduct an STAA every five years to evaluate the feasibility of implementing safer technologies and alternatives to reduce the risk of a catastrophic release. This analysis aims to encourage a safer way of doing things by adopting inherently safer design principles.
  4. Perform Thorough Incident Investigations: The updated standards emphasize the importance of thorough incident investigations following any release that meets or exceeds the threshold quantity. Facilities must identify and address the root causes of such incidents, as mentioned above.
  5. Conduct Emergency Response Exercises: Facilities must conduct annual tabletop and field exercises to test their emergency response plans and procedures. These exercises aim to ensure that facility personnel are prepared to respond effectively to emergencies. Although this process has been followed in the past, it is now required by the updated RMP standard.

How do the changes impact industry and surrounding communities?

By requiring facilities to implement more rigorous accident prevention measures, conduct third-party audits, and evaluate safer technologies, the USEPA aims to reduce the risk of catastrophic chemical releases and protect nearby communities and the environment. It’s important to note that a company that complies with OSHA PSM standards alone will no longer satisfy the new USEPA RMP standards and will need to take steps to update their programs.

What is the deadline for compliance?

USEPA identified compliance dates for various aspects of the program and provided guidance documents and resources to assist facilities in understanding and implementing the changes.

Facilities must update and resubmit RMPs to reflect new and revised data elements four years after the May 10, 2024 effective date.

EHS Support can help incorporate these changes by assisting with the development of stronger accident prevention measures, conducting third-party audits for your facility, and identifying safer technologies. Reach out to Allen Mires at allen.mires@ehs-support.com for additional information about the RMP or PSM standards.

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