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Dairy Facts 2016

EPA Proposes Changes to Risk Management Plan Regulations

Mar 30, 2016

The Environmental Protection Agency (EPA) last week proposed changes to its Risk Management Plan (RMP) regulations aimed to prevent accidental release of hazard chemicals. For dairy companies, this rule regulates anhydrous ammonia, the most commonly used chemical in industrial refrigeration systems, and chlorine, a chemical used in the wastewater treatment process.

These changes come after EPA held a Small Business Review panel in fall 2015 to review the impact the effect of proposed changes on regulated small businesses. IDFA participated on this panel.  

EPA proposes several changes to the Risk Management Plan regulations, including:

  • Root-cause analyses to be conducted during incident investigations;
  • Third-party compliance audits for certain regulated facilities;
  • Annual emergency response drills and exercises; and
  • Additional public access to RMP information.

Comments on these proposed changes are due May 13. IDFA’s Environmental Worker Safety Committee is in the processes of drafting comments on this proposed rulemaking.

Process Safety Management Regulatory Changes Coming

The Occupational Safety and Health Administration (OSHA) has a set of companion regulations called the Process Safety Management standard (PSM). This program was developed to ensure safe and healthy workplaces by requiring management of hazards associated with processes that use highly hazardous chemicals.

OSHA will be unveiling proposed changes to the PSM standard during a Small Business Review Panel in spring 2016.

Members with questions on the proposed changes may contact Emily Lyons, IDFA director of regulatory affairs and counsel, at

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