September 2016

Environment and Safety

Prospective costs of the EPA’s proposed RMP chemical accident prevention requirements

On March 14, 2016, the US Environmental Protection Agency (EPA) published proposed revisions to its Risk Management Plan (RMP) facility safety program in the US Federal Register.

Wilkinson, G., Pullins, T., Snow, C., Vinson & Elkins LLP

On March 14, 2016, the US Environmental Protection Agency (EPA) published proposed revisions to its Risk Management Plan (RMP) facility safety program in the US Federal Register. The proposed revisions include several changes to accidental-release prevention requirements, including: Third-party audits of an RMP program following an accident Considering inherently safer technology during hazard assessments Conducting root cause analysis of management failures in relation to an incident Taking actions to correct the root cause Sharing information with emergency planners and the public. The EPA describes these proposed revisions as improvements to lessons-learned processes. Facilities

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