Rulemaking - Ready, Set, Stop!
RMP Rule Amendments are Here !!
The EPA finalized the long-awaited amendments to its RMP Rule on December 21, 2016 and the Rule was published in the Federal Register on January 13, 2017.
The revisions will be effective 60 days after they are published in the Federal Register (FR) and facilities will have 1 to 4 years to implement the required changes.
EPA explained in a news release that, “This rule will help prevent chemical accidents, such as the explosion in West Texas in 2013, and their devastating effects.”
The news release went on to say that most facilities are operated safely, but “in the last 10 years more than 1,500 accidents were reported by facilities covered by the RMP Rule. These accidents are responsible for causing nearly 60 deaths; some 17,000 people being injured or seeking medical treatment; almost 500,000 people being evacuated or sheltered-in-place; and more than $2 billion in property damages.”
EPA indicates that these amendments are intended to:
The Final Rule (available here) with commentary and history is long at 111 pages. The first 103 pages provide discussion, both pros and cons, regarding the proposed legislation, and EPA’s reasoning for adopting its final amendments. Pages 4696 through 4705 outline the changes and provide the new language of the regulation.
A summary of the major changes is available on our RMP Amendment webpage.
There is some speculation over the internet that because of opposition from the regulated community and the new presidential administration, these amendments may not be implemented or they may be rescinded in their entirety.
Save the Dates
Schneider Risk Management (SRM) is teaming up with the City of Norton Shores, the Norton Shores Police Department, the Mona Shores High School Eco-Warriors and the Alliance of the Great Lakes to conduct a cleanup of Lake Harbor Park!!
Come help us make the beaches a safe and beautiful place to visit this summer.
Join us on April 15 and June 10, 2017!!!
By now you should be knee deep in assembling information reviewing data and getting ready to prepare and submit your Q1 reports.
OSHA 300A Logs – Your OSHA Log Posting is due February 1st. Make sure you have re-reviewed some 2016 incidents with your incident investigation team to ensure you have all the information you need and that it is still current. Sometimes reporting information changes weeks and even months after an incident so you want to be sure days away, transfer and other information is still correct.
Hazardous Waste Biennial Report – Review your waste shipping records to verify you have all the original signed manifests, LDR documents and waste characterization files for all wastes generated during 2016. Do a quick generator status check to determine whether or not your generator status has changed.
Tier 2 Reports – Has your company started any new processes this past year or started storing new chemicals on site? If so, determine the quantities you now store and how the materials are managed. This is a good time to update your chemical inventory.
Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual and annual reports to submit. It is a good idea to check in with the staff responsible for collecting the data to ensure it will be available when needed and it is accurate.
Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors in your home, the new year is a good time to check your online access user names and passwords to make sure they are current and still work. Some agencies require you to change your password annually. The new year is a good time to make sure that everyone involved in the reporting process still knows their login information. Getting these items resolved now will help avoid headaches as you approach reporting deadlines.
If you have questions, give us a call and we will be happy to help.