Update to the EPA RMP Rule. Part 7: Employee Participation

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We have completed our review of OSHA’s proposed changes to its process safety standard. Our discussions and analyses are provided in the book The OSHA Process Safety Standard: The 30-Year Update.

The EPA (Environmental Protection Agency) is going through a similar update process, as described in the post Updates to the RMP Rule. This is the seventh post in our series in which we review the EPA’s proposed updates. The proposed change that we consider in this post is to do with Employee Participation. (All comments refer to Scope 3 requirements.)

Prevention Program (Subparts C and D) Employee Participation

(1) Requiring employee participation in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
(2) Outlining stop work procedures in Program 3 employee participation plans.
(3) Requiring Program 2 and Program 3 employee participation plans to include opportunities for employees to anonymously report RMP-reportable accidents or other related RMP non-compliance issue

EPA Proposed Changes

The EPA is proposing changes in three areas: participation, stop work and anonymous reporting.