On May 17, 2018, the Environmental Protection Agency’s (EPA) Administrator requested public comment on several proposed changes to the final Risk Management Program (RMP) Amendments issued on January 13, 2017.

The EPA is proposing to rescind amendments relating to:

  • – Safer technology and alternatives analyses,
  • – Third-party audits,
  • – Incident investigations,
  • – Information availability, and
  • – Several other minor regulatory changes.

The EPA is also proposing to modify amendments relating to local emergency coordination, emergency exercises, public meetings, and to change the compliance dates for these provisions.


The RMP Reconsideration Rule proposes the following changes to the RMP Amendments final rule:

– Rescinding all accident prevention program provisions of the RMP Amendments rule (i.e., third party audits, safer technology and alternatives analyses, incident investigation root cause analysis, and most other minor changes to the prevention program) so that EPA can better coordinate revisions to the RMP rule with OSHA and its PSM standard and reduce regulatory costs. (An alternative proposal would retain
certain minor changes to the prevention program provisions.)

– Rescinding most of the public information availability provisions of the RMP Amendments rule that would have provided redundant, less secure means of access to information that is available through better –
controlled means, while retaining the provision requiring a public meeting after an accident but with minor language modifications.

– Modifying the emergency coordination and exercise provisions of the Amendments rule to address security concerns raised by petitioners and give more flexibility to regulated facilities in complying with these

If you have any questions regarding the Risk Management Program (RMP) Reconsideration Rule or would like further clarification as to its impact, please contact me at (919) 459-5245 or [email protected].