Illinois Fertilizer & Chemical Association
Supply · Service · Stewardship

Proposed RMP Rule Update

The Asmark Institute reports that EPA has proposed changes to the Risk Management Program (RMP) rule intended to strengthen the existing program and includes new safeguards that have not been addressed in prior RMP rules.  The proposal adds language to emphasize that natural hazards, loss of power and facility siting are among the hazards that must be addressed in Program 2 hazard reviews and Program 3 process hazard analyses.  
 
The proposal would require a formal root cause analysis incident investigation when facilities have had an RMP-reportable accident.  Third-party compliance audits could also be required based on accident history and the type of process at the facility.  Employee participation would be enhanced with several new requirements including requiring stop work procedures to be included in Program 3 employee participation plans.  There are new requirements for the facility to provide chemical hazard information upon request to residents living within 6 miles of the facility as well as a community notification system for informing the public about accidental releases.
 
The proposed compliance dates vary by the provision and could be 3 or 4 years after the effective date of the final rule.  Comments on the proposed rule will be accepted until October 31.  In addition to accepting written comments during the public comment period, EPA is also holding virtual public hearings on September 26, 27, and 28, 2022.