Update to the EPA RMP Rule. Part 3: Siting

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This is the third post in our series in which we review the proposed updates to the EPA’s (U.S. Environmental Protection Agency) Risk Management Program (RMP). This series complements the similar series that we have just completed for OSHA’s Process Safety Management (PSM) standard. The update process for the EPA rule is described in the post The EPA RMP Updates. As time permits, we will review and analyze each of their proposed changes. We will also compare them with the comparable OSHA update — where one exists. An index of the updates is provided here.

The third EPA item to consider is Siting. The pertinent section of their proposed update is shown below.

Prevention Program (Subparts C and D)
Siting

(1) Emphasizing that facility siting should be addressed in hazard reviews and explicitly define the facility siting requirement for Program 2 hazard reviews and Program 3 process hazard analyses. (2) Requiring a justification in the Risk Management Plan when facility siting hazard recommendations are not adopted.

OSHA Update

OSHA uses the words ‘Facility siting’ as part of paragraph (e) of its PSM standard. It provides no detail. The word is not mentioned in the proposed updates. The agency does not mention layout in either document.

Siting

The EPA states that it is requesting comments of the following.

• The Agency’s proposed approach.

The Agency does not provide guidance to do with the topic of Siting.

Siting and Layout