Update to the EPA RMP Rule. Part 4: Safer Technologies

This is the fourth 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 for OSHA’s Process Safety Management (PSM) standard.

The OSHA and EPA process safety programs derive their authority from the Amendments to the Clean Air Act of 1992. This legislation directed the two agencies to develop, implement and enforce process safety standards in order to protect both workers and the public. (This legislation also authorized the creation of the Chemical Safety Board.) Some states also introduced their own process safety regulations at roughly the same time.

The fourth EPA item to consider is ‘Safer technologies and alternatives analysis (STAA)’. The pertinent section of their proposed update is shown below. (All comments refer to Scope 3 requirements.)