On March 14, 2016, The Environmental Protection Agency (EPA) published proposed revisionsto the Risk Management Program (RMP) (also known as Accidental Release Prevention) rule at 40 CFR Part 68, under Section 112(r) of the Clean Air Act. The existing RMP rule requires facilities that hold more than a threshold quantity of certain hazardous substances to develop a risk management plan and to submit the plan to EPA. The proposed revisions stem from several industry incidents withmultiple fatalities that in turn led to President Obama’s 2013 Executive Order to relevant federal agencies to improve safety at facilities that use and distribute hazardous chemicals.

Significant proposed changes include the following...