SOCMA welcomes EPA’s final Risk Management Plan (RMP) Rule
22nd November 2019
The Society of Chemical Manufacturers & Affiliates (SOCMA) commends the U.S. Environmental Protection Agency (EPA) on its completion of the Risk Management Plan (RMP) reconsideration rulemaking that was released earlier today.
“SOCMA thanks Administrator Wheeler and EPA’s Office of Land and Emergency Management (OLEM) on finalizing the RMP reconsideration rule,” said Robert Helminiak, SOCMA Vice President of Legal and Government Relations. "SOCMA and its members have been actively engaged in the reconsideration of the 2017 RMP Amendments, and has been supportive of the Agency’s efforts to delay implementation of the prior rule while it conducted reconsideration proceedings. This final rule will provide much-needed certainty at facilities seeking to understand and achieve their RMP compliance obligations.”
SOCMA previously submitted comments on the RMP Reconsideration Proposed Rule in 2018 and is pleased that its recommendations are reflected in the language and provisions of the final rule.
The benefits of the RMP Reconsideration Rule are significant. The final provisions will support enhanced emergency response and preparedness among local communities while providing significant cost savings to regulated entities. SOCMA particularly commends the Agency in its complete rescission of requirements from the 2017 RMP Amendments Rule for third-party compliance audits, safer technology and alternatives analysis (STAA) and information availability. These requirements would have been highly costly, redundant and burdensome to RMP-regulated facilities if implemented, and would not have meaningfully contributed to reducing impacts from accidental releases.
RMP public data demonstrates that a high percentage of the same facilities are responsible for multiple accidents, while the vast majority of RMP facilities have never had a reportable accident. For these reasons, SOCMA has long supported a targeted approach that emphasizes more active EPA inspections and enforcement of existing RMP requirements. Doing so would address program areas that need better regulatory oversight while supporting the goals of the program.
Since its inception in 1996, the RMP rule has represented a mature and well-functioning accident prevention program that drives continuous improvement at chemical facilities and assists in the identification and reduction of risks, accidental releases and offsite impacts. SOCMA appreciates EPA’s efforts to resolve major concerns with the program and looks forward to working with the Agency on other regulatory matters impacting the specialty chemical industry in the future.