December 1, 2022

Volume XII, Number 335

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Here We Go Again: EPA's Proposed Changes to the RMP Program [VIDEO]

On August 31, 2022, EPA published a proposed rule that would make a number of key changes to the federal Risk Management Plan (RMP) program. The proposed changes would impact the scope of the Process Hazard Analysis (PHA), third-party compliance audits, employee participation requirements, and information sharing with the public and local emergency responders, among other requirements. The proposal would bring back to the program, with some tweaks, a number of changes that EPA had adopted in the final days of the Obama administration that never became effective and were subsequently rescinded as part of a 2018-2019 reconsideration proceeding. The public comment period on the proposed rule ends on October 31, 2022.

Join Bracewell ELR team members Steven Cook and Whit Swift as they discuss key elements of the proposed rule and how the changes, if adopted, will impact companies subject to the RMP program.

© 2022 Bracewell LLPNational Law Review, Volume XII, Number 274
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About this Author

Steven Cook Houston Environmental Attorney Bracewell
Of Counsel

Steven Cook advises clients on matters involving environmental and natural resources law and policy.

Prior to joining Bracewell, Steven worked for 22 years as corporate counsel at one of the world’s largest plastics and chemical companies. He also served as Deputy Assistant Administrator at the Office of Land and Emergency Management (OLEM) of the Environmental Protection Agency (EPA).

713-221-1366
Whit Swift, Bracewell Law Firm, Environmental Strategies Attorney
Partner

Whit advises industrial companies on state and federal air quality permitting and regulations, such as Title V operating permit matters and state and federal new source review permitting. He represents clients in environmental litigation matters and has contested permit matters before the Texas State office of Administrative Hearings.

He has experience assisting major manufacturing, energy, chemical, and petrochemical companies to develop and implement state and federal preconstruction and operating strategies, and provided counsel on compliance...

512-494-3658
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