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EPA’s Risk Management Program Rule Goes into Effect

Oct 10, 2018

The Environmental Protection Agency’s (EPA) 2017 Risk Management Program Amendments (RMP) rule went into effect Sept. 21 when a federal court rejected the administration’s efforts to delay its implementation. The regulation requires some dairy facilities to develop plans to avoid chemical accidents that include steps for preparedness, information sharing and coordination with emergency responders.

Dairy companies with over 10,000 pounds of anhydrous ammonia in industrial refrigeration systems, or those who have chlorine at their wastewater pretreatment facilities, are generally regulated under this EPA program.

The administration is working to finalize changes that would amend several of the 2017 rule’s requirements, a move that IDFA supports. Until those changes are final, however, IDFA encourages affected members to evaluate their plans and prepare for the current rule’s compliance dates.

The 2017 rule’s provision on coordinating emergency response activities is effective immediately.

Regulated companies have until March 15, 2021 to comply with requirements for third-party audits, incident investigation root cause analysis, enhanced public information sharing and emergency response exercises.

Read IDFA’s comments on the current effort to revise the RMP rule here.

Read EPA’s summary of compliance dates for more information.

Members with questions may contact Danielle Quist, IDFA senior director of regulatory affairs and counsel, at

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