Actions to Improve Chemical Facility Safety and Security under EO 13650, Improving Chemical Facility Safety and Security, Related to the EPA Risk Management Plan (RMP) Rule and OSHA Process Safety Management (PSM) Standard

Moll, Ashley; Frist, Bernie
(Partners (formally Greystone Environmental Management) and Safety & Risk Management Group, LLC)

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The OSHA Process Safety Management (PSM) Standard and EPA Risk Management Plan (RMP) Rule were implemented in the 1990s in order to control and minimize the risk of catastrophic releases of highly hazardous chemicals from processes within stationary sources. On August 1, 2013, POTUS issued Executive Order 13650 – Improving Chemical Facility Safety and Security (EO). The EO was in response to a series of chemical facility accidents that culminated with notable chemical facility accidents in West, Texas and Richmond, California. The EO directed the Department of Homeland Security (DHS), the EPA Environmental Protection Agency (EPA), the Department of Labor (DOL), the Department of Justice (DOJ), the Department of Agriculture (USDA), and the Department of Transportation (DOT) to establish a Chemical Facility Safety and Security Working Group to improve chemical facility safety and security in coordination with Stakeholders (State regulators; State, local, and tribal emergency responders; chemical facility owners and operators; and local and tribal communities). Fast forwarding to the present, what was the impact of the Executive Order? This presentation will discuss regulatory actions related to PSM and RMP as a result of the EO Working Group; the most significant being the EPA’s rulemaking to finalize amendments to the Accidental Release Prevention Requirements for Risk Management Programs under the Clean Air Act, Section 112(r)(7). The presentation will focus primarily on the changes to the EPA RMP regulation under the Final Rule, but will also discuss recent interpretation letters that have been issued by OSHA related to the PSM Standard. At the end of the presentation, attendees should have a better understanding of the regulatory changes resulting from the EO, and how to prepare their facilities for implementation deadlines.

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