The EPA Risk Management Program Update: Table of Contents

We have completed our review of the proposed changes to OSHA process safety standard (with stress on the word proposed — nothing is decided yet). Our analysis is provided in the book The OSHA Process Safety Standard — The 30-Year Update.

The U.S. Environmental Protection Agency (EPA) has also issued a proposed update to its Risk Management Program (RMP). The two proposals are similar, but definitely not identical.

Posts that we have published on the EPA proposed changes include,

• Updates to the EPA RMP Rule,

• Part 1: Natural Hazards,

• Part 2: Loss of Power,

• Part 3: Siting

• Part 4: Safer Technologies,

• Part 5: Root Cause Analysis,

• Part 6: Third-Party Audits,

• Part 7: Employee Participation, and

• Part 8: Community Notification.

One of the biggest differences between the OSHA and EPA proposals is their length and clarity. The OSHA proposal is just a few pages long, and not all that hard to follow. The EPA proposal is 60 pages in length, with each page being divided into three columns of dense text. It is difficult to follow and understand, not least because there are headings, sub-headings and sub-sub-headings. Finding one’s ways around their proposal is a challenge. And that challenge is made worse by the fact that there is no Table of Contents.

We have therefore prepared a Table of Contents for the EPA document. It is shown below. (The software for the posts at this blog does not support multiple, indented levels for an index or table, therefore we have provided the Table of Contents as a sequence of three images. All images are copyright © Ian Sutton, 2023.)