The U.S. Environmental Protection Agency is currently proposing to amend the Accidental Release Prevention Requirements of Risk Management Programs (RMP) under the Clean Air Act, Section 112(r)(7). The proposed changes are the result of a government effort to reduce chemical accidents, which became a federal priority after an explosion in West, Texas in 2013. Some of the revisions proposed by EPA that may impact printing facilities include:
- Clarifying language, such as substituting the term “imminent and substantial endangerment” with the phrase “impacts that resulted in deaths, injuries, or significant property damage on-site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.”
- Inclusion of a root cause analysis in investigations, which would require facilities to determine what caused an accident and would be included in RMP accident history reports.
- Requirement that facility owners and operators complete incident investigations within 12 months of either a catastrophic release or a near miss and would allow extensions of time for complex incidents, if approved by the agency in writing.
- More stringent audit requirements for program 2 and 3 facilities.
- Requirement that audit reports and documentation be submitted to the implementing agency and be available to the public
- Requirement that the owner or operator of a program 2 or 3 facility must coordinate with local response authorities to ensure that appropriate resources and capabilities are in place to respond to an accidental release of a regulated substance. If local emergency response capabilities are not adequate, EPA proposes that the facility be required to develop its own emergency response program.
- Development of a “score card” or grade system for RMP facilities. This grade would be available to the public.