Final EPA RMP Rule Leaves AN to OSHA – IME Major Concerns Addressed


Final EPA RMP Rule Leaves AN to OSHA – IME Major Concerns Addressed
December 22 – Yesterday, EPA Administrator Gina McCarthy signed the final rule updating the Risk Management Program (RMP) requirements companies must follow.  IME’s early review of the massive 372-page rule reveals that EPA understood our concerns detailed in personal meetings, official IME comments, and those submitted by member companies, and addressed them by leaving ammonia nitrate (AN) off of the list of chemicals subject to the rule’s requirements.  Based upon the initial review, IME is pleased that RMP requirements were not imposed on AN storage. 
IME has repeatedly stressed that AN does not pose the type of threat that RMP is intended to address, and requirements to comply with RMP would be superfluous and unlikely to incrementally increase the margin of public safety.  IME notes that the requirements of the Occupations Safety and Health Administration’s (OSHA) regulations at 29 CFR 1910.109(i) have served the nation well, as there has been no known accidental detonation of AN where companies have been in compliance with the regulations.  Recognizing this four-decades long safety record, IME has proposed to OSHA a series of amendments to strengthen the regulations for the next 45 years. 
IME is conducting a thorough review of the lengthy rule and will provide further comments at the appropriate time.