On February 25, EPA announced proposed revisions to its Risk Management Program (RMP) regulations under section 112(r) of the Clean Air Act, which require certain facilities to develop RMPs “to improve chemical process safety, assist local emergency authorities in planning for and responding to accidents, and improve public awareness of chemical hazards at regulated sources.” The proposal is in response to President Obama’s Executive Order (EO) 13650, “Improving Chemical Facility Safety and Security,” and draws on responses to a subsequent Request for Information (RFI) asking for preliminary feedback on potential changes.
In its 2014 comments on the RFI, AMWA stressed the importance of not mandating requirements related to the implementation of inherently safer technologies (ISTs). AMWA advised against the mandate due to the unique circumstances involved with water utilities’ selection of particular treatment processes and associated chemical usage. EPA’s proposal is in agreement with AMWA’s assessment and does not include IST mandates for the water sector. However, the plan does propose mandatory IST consideration for several other sectors and asks for further feedback on this and other administrative issues. AMWA plans to develop comments in response to the proposal.
Comments will be due to EPA within 60 days of the proposal’s publication in the Federal Register, which is expected in the next few weeks. Additional information on the RMP proposal, including links to the draft proposal, EO and RFI, is available through EPA’s RMP proposal webpage.