Recently the EPA published a Notice of Proposed Rulemaking (NPRM) in the Federal register proposing a revision to the RMP Rule incorporating several of the items which were discussed during the July 2014 Request for Information (RFI). The proposed rule change with the most impact on existing RMP programs is the requirement for third party audits. Although many RMP sites rely on external auditors, the impartiality, independence, and qualification requirements in these proposals will result in substantial changes in the way RMP compliance audits are conducted and reported.
The proposed changes in the emergency planning sub part of the RMP Rule could potentially force non-responding sites to become responding sites. This would be a fundamental change in emergency response commitment and requirements. The most important aspect of this proposed change is that the emergency response capability and readiness of local responders could determine this shift, not a voluntary move on the part of a covered site. The requirement for emergency response drills and exercises, while more formal in the proposed rule changes, is not a substantial change in current practice.
In response to this announcement, AcuTech Consulting Group has prepared a detailed white paper with an explanation of the proposed revisions to the RMP Rule concerning: Incident Investigation, Compliance Audits, Process Hazard Analysis, Emergency Planning, Public Access to RMP Information and other proposed changes.