May 4, 2016

RMP Modernization Rule- State/Local Consultation Teleconference Meeting

Attendees:

Office of Land and Emergency Management (OLEM)/Office of Emergency Management 

(OEM): Patty Gioffre, Kim Jennings, Jim Belke, Beth Bosecker, Kathy Franklin

Office of Land and Emergency Management (OLEM)/ Policy Analysis and Regulatory 

Management Staff (PARMS): Gerain Cogliano, Chris Prins

Office of the Administrator (AO)/Office of Congressional and Intergovernmental Relations 

(OCIR): Jack Bowles, Arnita Hannon Christmon, and Demond Matthews

US Conference of Mayors: Judy Sheahan, Rich Anderson

National League of Cities: Carolyn Berndt

National Association of Counties: Julie Ufner

Local Government Advisory Committee/Environmental Justice Workgroup: Dr. Hector 

Gonzalez

Statement of Concern: It is important when you respond to an incident, that a local government 

needs to know what to do and that public will know what to do. Emergency response plans, and 

any changes made to those plans, must be written in a manner that the community and the public 

will understand. Organizations representing state and local governments have not been properly 

briefed and the comment due date is May 13. We need more time to review.

Julie Ufner: Local communities and governments would be impacted by this proposal. Some 

have limited staff and are very small and don’t have the ability to do training and get the proper 

equipment for response.

Rich Anderson: Some of the charts in the presentation material give some pause and somehow a 

decision was made not to do a Federalism consultation because it was not required. Local 

governments have a part in this rulemaking process especially some of those in Program 2, 

which is showing a low count of regulated facilities. In every locality, we would be required to 

be responders. We also have a dual role- as regulated facility and as part of a response team. 

Many drinking water treatment staff are often first responders. Our organizations take on several 

roles: city who coordinates emergency response, emergency responders, and part of the 

regulated sources. The ICR (Information Collection Request) lacks sufficient cost data on local 

governments. Consultation with these entities should happened before issuing a proposed rule. 

The Federal government delegates some programs to states. It appears that facilities in nonFederal OSHA states are in Program 3 on Slide 6. There are just about 10,000 facilities in that 

Program. How does that compare with approximately 54,000 municipal water systems and 

20,000 waste water treatment plants which total some 70,000 facilities that could be impacted?
Jim Belke: The proposal does not alter the universe of regulated facilities. We are not adding 

any new chemicals, changing reporting threshold quantities and changing the scope of facilities 

covered. Many water treatment facilities are not covered by RMP because they do not have the 

threshold quantity of regulated substance on-site. The list of regulated chemicals covers 

chemicals such as chlorine, ammonia and sulfur dioxide. The status of OSHA PSM (Process 

Safety Management standard) coverage affects whether a facility is covered under RMP Program 

2 or 3. Facilities subject to the OSHA PSM standard are subject to RMP Program 3 

requirements. Government-run facilities such as municipal water treatment facilities that are 

covered under OSHA state plans are in Program 3. Municipal state employees in Federal OSHA 

states are not covered under PSM, therefore they fall into Program 2.

Q. Who is qualified to do third party audits?

Jim Belke: The proposal sets out qualification and independence criteria for third party auditors. 

The proposal specifies that a professional engineer must be part of the audit team, the auditors 

must be qualified to do audits and they must be knowledgeable about the facility’s process. 

There are no more specific criteria proposed for qualification. We are seeking comment on the 

criteria. Small businesses through our small business review process, have indicated some 

concerns about the independence criteria and how it would affect the availability of qualified 

auditors. 

Q: How would one find a third party auditor?

Jim Belke: There are existing auditors that perform process safety audits that could be third 

party auditors. Some regulated facilities already use third party auditors to conduct the required 

compliance audit, although they are not required to. EPA did not attempt to evaluate the existing 

capacity of firms that provide process safety auditing services, and we are interested in receiving 

public comments on this issue. 

Patty Gioffre of EPA/OEM then made a presentation on the RMP Modernization Rule, see 

Powerpoint Presentation below.
Risk Management 

Modernization 

Rule 

STATE/LOCAL CONSULTATION 

MAY 4, 2016

OFFICE OF LAND AND EMERGENCY MANAGEMENT

OFFICE OF EMERGENCY MANAGEMENT
Agenda

Background 

Overview of proposed rule provisions and costs

State/local government impact 

Additional resources 

Questions

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Background

On August 1, 2013, President Obama issued Executive Order (EO) 

13650: Improving Chemical Facility Safety and Security following several 

catastrophic chemical facility incidents in the United States

◦ Focus is to reduce risks associated with hazardous chemicals to owners and 

operators, workers, and communities by enhancing the safety and security of 

chemical facilities

The keys areas of emphasis under the EO are:

◦ Strengthening community planning and preparedness,

◦ Enhancing federal operational coordination,

◦ Improving data management, and

◦ Modernizing policies and regulations

◦ EPA issued a request for information (RFI) on July 31, 2014, and 

◦ Convened a Small Business Advocacy Review panel on November 4, 2015

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Existing regulatory framework

The Risk Management Program is one of several programs that 

address chemical facility safety and security:

◦ OSHA Process Safety Management (PSM) standard - Management program 

for highly hazardous chemicals aimed at preventing and minimizing 

occupational/onsite exposure

◦ Emergency Planning and Community Right-to-know (EPCRA) requirements - Local emergency planning and preparedness, emergency release 

notification, community right-to-know: provision of hazardous chemical 

storage inventory and toxic chemical release inventory to the community 

and first responders

◦ CAA Section 112(r)(1) general duty clause - Facility owner/operators have a 

general duty to prevent and minimize releases

◦ Chemical Facility Anti-terrorism Standards (CFATS) - DHS security 

requirements 

◦ ATF requirements for explosives

◦ State/local requirements (e.g., NJ, Contra Costa County, CA regulations)

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Risk Management Program rule

◦ Promulgated in 1996 under Section 112(r) of the Clean Air Act 

Amendments

◦ Applies to all stationary sources with processes that contain more than a 

threshold quantity of a regulated substance (approx. 12,500 sources)

◦ Includes a wide variety of industry sectors including: refining, chemical 

manufacturing, energy production, ammonia refrigeration, water treatment, bulk 

storage, chemical distribution, agricultural retail, and chemical warehouses 

◦ Requires the source to develop a Risk Management Plan (RMP) 

◦ Addresses elements aimed at preventing accidental releases and reducing the 

severity of releases that occur

◦ Prepare and submit an RMP to EPA at least every 5 years

◦ Covered processes fall within one of three prevention program levels 

based on:

◦ The potential for offsite consequences from a worst-case accidental release;

◦ Accident history; and

◦ Regulation under OSHA PSM

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Program levels

PROGRAM 1

642 Facilities

Processes not eligible 

for Program 1, not 

subject to Program 3

◦ Mainly water & 

wastewater treatment in 

Federal OSHA states

◦ Additional hazard 

assessment, accident 

prevention, management, 

and emergency response 

requirements

PROGRAM 2

1,272 Facilities*

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*Analysis reflects OSHA change to PSM retail exemption issued July 2015. See OSHA PSM Retail

Exemption Policy at: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=2 9528

6

Processes subject to 

OSHA’s PSM or in one of 

10 specified NAICS 

codes

◦ Larger facilities or those 

with complex processes

◦ Examples include: refining, 

chemical manufacturing, 

energy production, water 

treatment

◦ Covered by OSHA’s PSM 

accident prevention 

program and include 

additional hazard 

assessment, management, and 

emergency response 

requirements

PROGRAM 3

10,628 Facilities*

Processes that would 

not affect the public in 

the event of a worst- case release & no 

accidents with offsite 

consequences in the last 

five years

◦ Small quantities of 

flammables, less volatile 

toxics

◦ Limited accident 

prevention including 

hazard assessment and 

emergency response 

requirements
Program level comparison

PROGRAM 1 PROGRAM 2 PROGRAM 3

• Worst case analysis

• 5-year accident history

• Document management system

• Worst case analysis

• 5-year accident history

• Document management system

• Worst case analysis

• 5-year accident history

• Document management system

Prevention Program

Certify no additional prevention steps 

needed

• Safety information

• Hazard review

• Operating procedures

• Training

• Maintenance

• Incident investigation

• Compliance audit

• Process safety information

• Process hazard analysis (PHA)

• Operating procedures

• Training

• Maintenance

• Incident investigation

• Compliance audit

• Management of change 

• Pre-startup review 

• Contractors

• Employee participation

• Hot work permits

Emergency Response Program

Coordinate with local responders Develop plan/program and coordinate 

with local responders

Develop plan/program and 

coordinate with local responders

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Overview of Proposed Revisions

P1 P2 P3

Third-party audits (applies to the next scheduled audit after an 

accident) [Estimated 150 accidents/year]

√ √

Incident Root Cause Analysis (only for facilities with 

accidents/near misses) [Estimated 300 incidents/year]

√ √

Safer Alternatives Analysis (applies to a subset of P3 in certain 

NAICS codes*) [Estimated 1,692 Facilities/4,308 Processes]

√

Coordinating Emergency Response Program Requirements 

with Local Responders

√ √

Emergency Response Exercises √ √

Information Sharing √ √ √

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*Applies to paper manufacturing, petroleum and coal products manufacturing, and 

chemical manufacturing facilities 
Third-party compliance audits

Proposed revisions require all P2 and P3 facilities to conduct a thirdparty audit in lieu of a compliance audit following an RMP reportable 

accident.* 

◦ Must be completed within 12 months of an RMP reportable accident or 

within 3 years of completion of the previous compliance audit, whichever is 

sooner. 

◦ Note that this audit and its schedule are independent of the incident investigation 

requirement and its schedule.

◦ Same scope as the current compliance audit provisions (i.e., audit 

prevention program implementation for all covered processes).

◦ EPA is proposing criteria for auditor independence, impartiality, and 

competence.

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* RMP reportable accident means an accidental release meeting the criteria in §68.42(a) 

from a covered process at a stationary source (i.e., includes accident with deaths, 

injuries, evacuations, sheltering in place, property damage, or environmental damage).
Incident investigations and 

root cause analysis

Proposed revisions (Applies to P2 and P3): 

◦ Revise incident investigation requirements to:

◦ Clarify that it applies to a catastrophic release (i.e., an RMP reportable accident) or 

an incident that could reasonably have resulted in a catastrophic release (i.e., a near 

miss) 

◦ Require a root cause investigation (i.e., identify the fundamental reasons why an 

incident occurred and the correctable failures in management systems)

◦ Require a report be completed within 12 months (unless extension approved, in 

writing, by implementing agency)

◦ Clarify the definition of catastrophic release to be consistent with reportable 

accidental release (i.e., an accident with deaths, injuries, evacuations, 

sheltering in place, property damage, or environmental damage)

◦ Add a definition of root cause to mean a fundamental, underlying, systemrelated reason why an incident occurred that identifies correctable failure(s) 

in management systems

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Safer technology and 

alternatives analysis (STAA)

Would apply to P3 facilities in NAICS 

codes:

◦ 322 (paper manufacturing), 

◦ 324 (petroleum and coal products 

manufacturing), and 

◦ 325 (chemical manufacturing) 

The STAA would consider, in the 

following order of preference:

◦ Inherently safer technology (IST) or design, 

◦ Passive measures, 

◦ Active measures, and 

◦ Procedural measures

ISTs are those measures that reduce or 

eliminate the hazards and include 

minimization, substitution of less 

hazardous chemical, moderation of 

the process, and simplification of the 

process/procedures

Owner/operator would not be 

required to implement any prescribed 

technology; however EPA is requesting 

comment on whether the rule 

should require implementation

EPA is proposing several

definitions including feasible

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Proposed revisions to require the source to conduct a STAA and 

determine feasibility of inherently safer technologies and designs 

considered:
Local coordination

Proposed revisions require all P2 and P3 facilities to:

◦ Coordinate annually with the Local Emergency Planning Committees (LEPCs)/emergency responders and ensure response capabilities exist ◦ Document coordination ◦ LEPCs/emergency responders can request source to prepare an emergency response 

(ER) program

What are the outcomes of “coordination”?

◦ “Non-responding” source – coordination 

indicates that local public response 

capabilities are adequate to respond, 

appropriate notification mechanisms are in 

place, and local authorities have not 

requested that owner develop ER program

◦ “Responding” source – coordination indicates 

that local public response capabilities are not 

adequate to respond, or local authorities 

request that owner develop ER program 

◦ Facility must develop an emergency 

response program following § 68.95

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What is “coordination”?

◦ Facility and local responders meet and 

discuss response needs, capabilities, and 

roles:

• Determine resources needed to 

appropriately respond to regulated 

substance releases at facility

• Determine resources available from facility 

and local responders

• Identify capability gaps and develop plans 

to address

• Decide whether facility or local responders 

will respond to releases of regulated 

substances

• Assign response action roles and 

responsibilities
Exercises

Proposed revisions: Require facilities to test their emergency response 

program through notification, tabletop, and field exercises (Applies to all 

P2 and P3)

◦ Require “responding” and “non-responding” facilities to conduct an annual notification exercise

◦ Require “responding” facilities to conduct the field and tabletop exercises and 

invite local responders to participate:

Tabletop exercise

◦ Frequency: Annually except in the year 

of a field exercise

◦ Scope: Same as field exercise without 

actual mobilization of personnel & 

equipment

An exercise evaluation report must be 

completed within 90 days

of each exercise.

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Field exercise

◦ Frequency: Every 5 years and within one 

year following a reportable accident

◦ Scope: Test procedures for notification, 

evacuation, medical treatment, 

communications systems, emergency 

response personnel mobilization 

(including contractors, if appropriate), 

coordination with local responders, 

equipment deployment, and other actions 

identified in ER program as appropriate
Information sharing

Proposed revisions add new disclosure elements for all facilities:

◦ To LEPCs and emergency responders

◦ To general public

◦ Public meetings within 30 days of an RMP reportable accident

The information should be conveyed without revealing CBI or trade 

secret information

Any summary information should adequately explain the findings, 

results, or analysis being provided while avoiding technical jargon

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Information sharing-LEPC

Require summaries of chemical hazard information to be provided to 

LEPC or local emergency response official, upon request:

◦ Information on RMP regulated substances−names and quantities of 

regulated substances held in a process

◦ Five-year accident history information (reported under §68.42)

◦ Compliance audits

◦ Incident investigation reports (with root cause findings)

◦ IST implemented or planned to be implemented, if applicable

◦ No requirement to implement, but if a source does implement ISTs it is 

useful information for LEPCs/first responders to have in their local 

emergency planning efforts

◦ Exercises, including schedules and reports

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Information sharing-public

Require chemical hazard information to be provided in an easily 

accessible manner (i.e., posting on a company website, public file sharing 

website, or social media website, or placing a file at a public library or local 

government office)

◦ Names of RMP regulated substances held in a process

◦ Safety data sheets (SDS) for all RMP regulated substances located at 

the facility

◦ Emergency response program summary information 

◦ Five-year accident history information reported under §68.42

◦ Exercise summary information

◦ LEPC contact information

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Information sharing- public meetings

Proposed revisions would require a public meeting to be held within 30 

days of an RMP reportable accident. The meeting would address:

◦ Information about the accident;

◦ Other relevant chemical hazard information (such as what would be provided 

to the public)

Can be held in concurrence with a regularly scheduled LEPC meeting that 

is open to the public

Facilities must notify the community about the public meeting and can 

use various methods including: 

◦ Publishing a notice in a local paper, 

◦ Social media, and/or 

◦ Fliers in public places, like the local library

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Estimated unit costs (in actual $)*

Type of Cost Estimated 

Compliance Cost* Notes

Third-party Compliance 

Audits $18,000 to $49,000 Applies to facilities with P2 and P3 processes after an RMP reportable accident.

Incident Investigation Root 

Cause Analysis $2,000 to $5,000 Applies to facilities with P2 and P3 processes only after an RMP reportable accident or a near miss.

STAA $29,000 to $49,000 

per process

Applies to facilities in select NAICS codes with P3 processes. 

Occurs once every 5 years.

Coordination with local 

responders $300 to $400 Applies to P2 and P3 facilities. Occurs annually.

New Responder Costs (estimated costs that may apply if a current non-responding facility becomes a responding facility as a 

result of local coordination activities)

Develop Plan $2,000 to $8,000 Initial year costs. New responders will also be subject to 

exercises costs below. Train employees $11,000 to $65,000

Purchase equipment $50,000 to $60,000

Emergency Response Exercises (P2 and P3)

Notification drills $100 to $200 Applies to both responders and non-responders. Occurs 

annually.

Tabletop exercises $5,000 to $24,000 Applies to responding facilities. Tabletop exercises occur 

annually except in the year of a field exercises which occurs 

once every five years. Field exercises $8,000 to $66,000

Information Sharing (All RMP facilities)

LEPC/TEPC/local 

responders $4,000 to $10,000

These ranges represent the combined costs for all required 

reports. Costs will vary on an annual basis upon occurrence 

of regulatory requirements (e.g., compliance audits, incident 

investigations).

Public $200 to $1,600 Update annually.

Public meetings $2,000 to $4,000 After an RMP reportable accident.

* Sources for 

estimates 

include 

technical 

literature, 

public 

comments, 

other similar 

programs, 

RMP 

database, 

and EPA 

labor models 

18
How Could This Proposed Rule 

Impact State and Locals?

Governments could be impacted by this proposal in 2 ways:

◦ As a local government when conducting emergency response or emergency 

preparedness activities under EPCRA

• LEPCs or local emergency responders would coordinate with RMP-regulated facilities 

for community planning and preparedness activities

• The LEPC or local emergency response officials would be able to request specific 

information from the facility for planning purposes

• The local emergency responders may be requested to participate in exercises by 

RMP-regulated facilities 

◦ As an owner or operator of an RMP-regulated facility

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LEPCs can also request RMP-regulated facilities to develop an emergency 

response program as described in Subpart E of the rule (40 CFR 68.95)
20

Non-federal Emergency Response Entities Under EPCRA

SERCs TERCs LEPCs TEPCs

State Emergency

Response 

Commissions

Tribal Emergency

Response Commissions

Local Emergency

Planning 

Committees

Tribal Emergency

Planning Committees

SERCs are 

appointed by the 

governor of each 

state to establish 

LEPCs.

TERCs are established by 

the Chief Executive Officer 

of the tribe. TERCs have the 

same responsibilities as 

SERCs in the Tribal region.

LEPCs are 

established by 

the SERC in each 

state. 

TEPCs are established by 

the TERC. They have the 

same responsibilities as 

LEPCs in the tribal region.

Responsibilities

• Establish and supervise LEPCs / TEPCs 

• Review local emergency plan 

• Establish mechanisms to collect hazardous 

chemical inventories and information on chemical 

releases from facilities

• Establish procedures to process public information 

requests

Responsibilities

• Prepare and review chemical emergency 

response plan

• Coordinate responses to emergency releases, 

serving as a focal point in the community for 

information and holding discussions about 

chemical risks in the community

• Establish procedures to process public 

information requests

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Additional resources

RMP proposed rule webpage: 

http://www.epa.gov/rmp/propose

d-changes-risk-management- program-rmp-rule

Submit comments: 

www.regulations.gov

Docket ID# EPA-HQ-OEM-2015-0725

Comments close May 13, 2016

EO activities under EO 13650: 

http://www.epa.gov/rmp/executiv

e-order-improving-chemical- facility-safety-and-security

EO 13650: 

https://www.osha.gov/chemicalex

ecutiveorder/index.html

Report for the President: Actions 

to Improve Chemical Facility Safety 

and Security–A Shared 

Commitment: 

https://www.osha.gov/chemicalex

ecutiveorder/final_chemical_eo_st

atus_report.pdf

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Questions?

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22
May 4, 2016

RMP Modernization Rule- State/Local Consultation Teleconference Meeting

Questions and Answers after the Presentation:

Q: For government-run facilities and first responders, it would have been nice to have a 

consultation on the proposed rule earlier. Would the comment period be extended? We will 

provide a request to extend the comment period.

Patty Gioffre: Our management has not granted previous requests to have the comment period 

extended. This rule is an Agency priority and we are trying to move the process forward.

Q: EPA is usually involved in Federalism outreach activities due to its delegation of programs. 

Is there a map available that shows where all the RMP facilities are located? That would help us 

in targeting outreach and concerns.

Jim Belke: Yes, there are maps, but that is considered security sensitive information and the 

Agency is not willing to post any state or local maps showing locations of RMP facilities that 

could potentially be used by criminals or terrorists.

Q: How would we let facilities know about the new requirements?

Jim Belke: We regularly do outreach to organizations that represent local governments. For 

example, we meet and talk with the National Association for SARA Title III Program Officials 

(NATTSPO) that specifically deals with state and locals involved in emergency planning issues. 

There are several trade associations representing water treatment facilities. We would like to 

hear about other mechanisms to reach regulated facilities.

Q: We would recommend providing at least a list of cities and counties impacted to help get the 

word out. This would help.

Kim Jennings: We do outreach regularly with a monthly SERC/TERC update (SERC: State 

Emergency Response Commission, TERC: Tribal Emergency Response Commission) that 

provides news on upcoming meetings, training, etc. Those SERCs are very connected to their 

LEPCs (Local Emergency Planning Committees) and they would rather provide information to 

those organizations at that level. These state organizations also like to use their own electronic 

data systems to provide new information and updates to local governments.

Patty Gioffre: LEPCs are also made up of various members of the public, local response 

agencies, other government agencies, medical professional, and representatives of regulated

facilities who can share information from various sources.
Q: Local governments can opt out of being responders. Does that affect the cost analysis? If the 

facility is a POTW (publicly owned treatment works), then those are costs that affect local 

government. Do the cost estimates include equipment and personnel needed for response as well 

as training?

Jim Belke: Estimating how many facilities would become new responders as a result of the 

proposed rule was not easy. We looked at existing RMP data to determine how many facilities 

were non-responding and that was about 60%. We tried to determine how many of those nonresponders might become responders by reviewing information on how close existing hazmat 

teams were located to facilities. We did a sensitivity analysis to estimate the range of facilities 

that might become new responders. The estimated costs do include personnel needed and 

equipment and we looked at the HAZWOPER (Hazardous Waste Operations and Emergency 

Response) training requirements involved.

Patty Gioffre: We also looked at the government facility costs differently. Some local 

governments may have responders that already can cover more than one RMP facility. Regulated 

local government facilities may also be able to conduct joint exercises and, if necessary, joint 

public meetings.