New Updates to Risk Management Plans: Enhancing Safety Standards for Chemical Facilities and Promoting Environmental Justice.

In a significant move to enhance public safety and environmental justice, the U.S. Environmental Protection Agency (EPA) announced on March 1, the finalization of amendments to the Risk Management Program (RMP). Dubbed the "Safer Communities by Chemical Accident Prevention Rule," this landmark regulation introduces the most protective safety provisions in history for chemical facilities, particularly targeting industry sectors with high accident rates. The rule is designed to shield at-risk communities, especially those in overburdened and underserved areas, from the devastating impacts of chemical accidents. EPA Administrator Michael S. Regan emphasized that this final rule is a vital component of the Biden-Harris Administration's commitment to advancing environmental justice by implementing stronger safety requirements for industrial facilities and new measures to protect communities from harm.


Key Provisions of the Rule


The final rule mandates more stringent measures for prevention, preparedness, and public transparency, with the aim of preventing accidental releases of dangerous chemicals that could lead to fatalities, injuries, property damage, or environmental harm. Key provisions include:


  • Safer Technologies and Alternatives Analysis: Regulated facilities are now required to perform an analysis of safer technologies and alternatives. In some cases, they must implement reliable safeguard measures to reduce the frequency and severity of accidents.
  • Empowering Workers: The rule advances employee participation, training, and decision making in facility accident prevention. It allows for process shutdowns in the event of a potentially catastrophic release and establishes a process for employees to anonymously report unaddressed hazards.
  • Third-Party Compliance Audits: Facilities with a prior accident history must undergo third-party compliance audits and conduct root cause analysis investigations. - Enhanced Emergency Response: Facilities must ensure timely sharing of chemical release information with local responders and establish a community notification system for impending releases.
  • Climate Change Considerations: Facilities are required to evaluate risks of natural hazards and climate change, including potential power loss, and increase transparency by providing access to RMP facility information for nearby communities.


The Impact of the Rule

The rule covers all 11,740 regulated RMP facilities across the country, with more rigorous requirements for a subset of facilities that are more accident-prone and pose the greatest risk to communities. According to EPA estimates, accidental releases from RMP facilities cost society more than $540 million each year. Approximately 131 million people live within three miles of RMP facilities, including 20 million who identify as Black or African American, 32 million as Hispanic or Latino, and 44 million who earn less than or equal to twice the poverty level.


The rule will be published alongside a query tool which will allow people to access information for RMPs in nearby communities. The agency intends to update the tool in the coming months to allow visualization of climate change hazards, a request of several stakeholders.


How SEA Can Help


At Safety & Environmental Associates, Inc. (SEA), we understand the complexities of complying with evolving safety standards and regulations. Our team of experts is equipped to assist your company in updating your Risk Management Program to meet the new requirements set forth by the EPA. We offer comprehensive services, including safer technologies and alternatives analysis, employee training programs, third-party compliance audits, and emergency response planning.


Don't wait until it's too late and EPA is knocking on your door. Contact SEA today to learn more about how we can help you comply with the new RMP rule and protect your business and the environment.


Read more information on the rule visit EPA’s Risk Management Program rule website.


By Derek Jennings

Contact SEA Inc. Today!

California Tightens Lead Exposure Limits

By Derek Jennings • March 31, 2025
California Tightens Lead Exposure Limits: What Employers Need to Know

OSHA’s Top 10 Most Cited Health and Safety Violations of 2024 a Deeper Look!

By Derek Jennings • February 10, 2025
Each year, as the Occupational Safety and Health Administration (OSHA) releases its list of the top 10 workplace safety violations, a pattern emerges that begs a question: Are these frequent violations a sign that employers continue to struggle with the same safety issues, or does it reflect a disposition among OSHA inspectors to focus on areas where they are trained to focus? The Persistent Issue of Repeated Findings The repetition of certain violations year after year might seem surprising, but it underscores a significant challenge in workplace safety management. The top violations tend to be those that are most visible and easiest to spot during inspections, such as fall protection and hazard communication. This consistency suggests that while awareness is high, practical implementation and adherence to safety practices lag behind. Top 10 Most Cited Health and Safety Standards of 2024 1. . Fall Protection, General Requirements: 6,307 violations For the 14th consecutive year, fall protection tops the list of OSHA's enforcement priorities. This emphasis is not arbitrary; OSHA has designated fall protection as a national emphasis area, making it a primary focus during inspections. It's often one of the easiest violations to spot without extensive investigation skills. The OSHA standard 1926.501 mandates that employers must provide fall protection systems like guardrails, safety nets, or personal fall arrest systems for workers at risk of falls of six feet or more in construction and four feet in general industry. Often, the major factor in these violations is human behavior. Many offenders might think, "No one is watching, and this will only take a moment, so it's no big deal." However, this mindset can lead to non-compliance with critical safety measures, putting worker safety at significant risk.

Navigating OSHA's New Arc Flash Guidance - What Employers Need to Know

By Derek Jennings • February 7, 2025
The Occupational Safety and Health Administration (OSHA), in collaboration with the Partnership for Electrical Safety and KEMA Laboratories, has recently unveiled new guidance aimed at addressing arc flash hazards in the workplace. This guidance is a crucial update that highlights the need for comprehensive electrical safety programs that specifically include measures to protect against arc flash hazards. Here’s what employers need to understand about the new directives and how they can effectively respond. Understanding Arc Flash and OSHA's Recommendations An arc flash is a type of electrical explosion that results from a low-impedance connection to the ground or another voltage phase in an electrical system. The new guidance provided by OSHA not only offers a clear definition of what constitutes an arc flash but also elaborates on methods to mitigate such hazards during electrical work. The guidance includes detailed documents for employers and useful handouts for employees, emphasizing the common myths and the reality of arc flash dangers. The Role of NFPA 70E OSHA’s guidance strongly correlates with the standards outlined in NFPA 70E, the National Fire Protection Association’s standard for electrical safety in the workplace. Employers who are already compliant with NFPA 70E likely have a written Electrical Safety Program (ESP) that includes protocols for arc flash hazards. This new guidance serves to reinforce the importance of these existing standards while also urging those without comprehensive plans to take immediate action. What if You Don’t Have a Comprehensive ESP? For employers who have yet to develop an ESP that addresses arc flash hazards, OSHA’s guidance is a wake-up call. It is crucial to recognize that general workplace safety standards, although not specifying arc flash, require protection against electrical hazards under regulations like 1910.333. The absence of specific OSHA standards for arc flash does not excuse employers from the responsibility of protecting their employees from such risks. Implementing Effective Arc Flash Protection Measures Incident Energy Analysis: A foundational step in arc flash protection is conducting an incident energy analysis. This process involves studying the facility’s electrical systems to calculate the potential energy released in the event of an arc flash. Understanding this energy potential is essential for determining the arc flash boundary—the distance within which a person could receive second-degree burns or worse if exposed to an arc flash. Developing a Risk Assessment Procedure: Employ ers need to establish a procedure for assessing the risks associated with arc flash. This includes evaluating the tasks being performed, the condition of the electrical equipment, the maintenance history of the equipment, the energy involved, and the potentia l for human error. Deciding on Protective Measures: Once risks are assessed, decisions must be made regarding the best ways to protect employees. This often involves the use of Arc-Rated Pe rsonal Protective Equipment (PPE) and could also include engineering controls such as redesigning parts of the electrical system to minimize arc flash risks. Proactive Versus Reactive: The Choice is Yours The latest guidance from OSHA should be viewed as an unofficial yet critical call to action for employers to either update their existing safety measures or develop new protocols in line with NFPA 70E. Being proactive about electrical safety not only helps in compliance with OSHA’s standards but fundamentally enhances the safety and well-being of employees. Final Thoughts The introduction of OSHA’s arc flash guidance is a significant step toward heightened awareness and improved safety practices surrounding electrical hazards in the workplace. Employers are encouraged to review their current safety protocols, educate their workforce about the dangers of arc flash, and implement comprehensive measures to prevent such incidents. Always keep in mind that workplace safety begins with staying informed and well-prepared. Make it a habit to test before you touch it and prioritize safety like your life depended on it! For more insights into workplace safety and compliance, keep following our blog. Your safety is our priority, and together, we can foster a safer working environment for all. By Derek Jennings  President SEA
Show More