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Risk Management Plan rule (RMP)
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Safety and health of the community
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Environmental Protection Agency
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40 CFR 68
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EPA published a Proposed Rule and accepted comments until May 13, 2016
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• Include reactive chemicals, high and/or low explosives, and ammonium nitrate as regulated substances.
•Enhance development and reporting of worst case and alternate release scenarios; and
• Add new prevention program requirements, including automated detection and monitoring, contractor selection and oversight, public disclosure of information, and, for petroleum refineries, attributes of goal-setting regulatory approaches.
Full CSB Response to Request for Information (RFI)
CSB response to the EPA's March 14, 2016, Proposed Rule, “Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Action, Section 112(r)(7).
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Process Safety Management Program (PSM)
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Minimizing risks to employees
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Occupational Safety and Health Administration
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29 CFR 1910.119
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OSHA initiated the Small Business Regulatory Enforcement Fairness (SBREFA) panel - meetings occuring during June 2016 and open to the public
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•Include the Oil and Gas Sector and reactive chemicals in the rule’s coverage.
• Provide stop work authority to employees;
• Update existing Process Hazard Analysis requirements to include the documented use of inherently safer systems, hierarchy of controls, damage mechanism hazard reviews, and sufficient and adequate safeguards;
• Develop requirements for facility/process siting and human factors
• Require coordination of covered facility emergency plans with local emergency response authorities; and
• Permit third-party compliance audits.
Full CSB Response to Request for Information (RFI)
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