Mr. Michael Hazzan and Mr. Mark S. Dreux, led a webinar to discuss key issues in a Request for Information (RFI), that was published in the Federal Register.

Thank you for attending the August 7 Webinar on EPA RFI!

If you missed it, please click to download the slides.

The RFI addresses the following areas with respect to possible changes to the RMP regulation (40 CFR 68):

  • Items in OSHA’s RFI relevant to EPA’s RMP regulation, including changes to covered chemicals, third party audits, MI program changes to cover all critical equipment, definition of RAGAGEP, and others.
  • Additional changes to RMP Regulation, including emergency drills, automated detection and monitoring for releases, Worst Case Release scenario modifications, public disclosure of information, threshold quantities and off-site consequence analysis endpoints, streamlining RMP requirements, and others.
  • Promoting Safer Technology and Alternatives, i.e., inherently safer technologies (IST).
  • Safety Case regulatory model.

Michael Hazzan, P.E., CPSA has over thirty-three years’ experience in process safety and risk analysis, process security, engineering, and plant operations.  He has served as a Project Manager/Lead Engineer for a number of safety and risk studies, security analyses, and audits.  This work has comprised extensive experience in PSM/RMP auditing (over 100 such audits in the past 12 years), security vulnerability analyses (SVA), process hazard analyses (PHA), release (source term) calculations for severe reactor accidents, facility siting studies, and dispersion/consequence calculations, development of mechanical integrity management systems, and probabilistic risk analyses.

Mark S. Dreux, Esq. is the head of the OSHA Group in Arent Fox’s Labor & Employment Practice and is nationally recognized for his work in occupational safety and health law. Mark focuses on representing employers and trade associations in all aspects of the Occupational Safety and Health Act (OSH Act). His practice includes counseling clients in regulatory compliance with the standards and regulations which OSHA and the state plans have promulgated, investigating significant workplace incidents, managing OSHA inspections, contesting OSHA citations, defending employers in OSHA enforcement actions, conducting safety and health audits and due diligence reviews, and engaging in regulatory advocacy.

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