In 2024, after several rounds of legislative action, lawsuits, and rulemaking, the US Environmental Protection Agency (EPA) finalized changes to its Risk Management Program (RMP) rule under the title “Safer Communities by Chemical Accident Prevention Rule.”
This revised rule established new guidelines for organizations handling hazardous chemicals, who must now ensure greater protection for communities, first responders, and the environment.
While compliance deadlines extend to 2027–2028, small-to-mid-sized organizations, unlike their larger counterparts, face unique implementation challenges that require immediate attention.
Why this matters for small and mid-sized organizations
The RMP emphasizes the importance of informed decision-making, encouraging businesses to collaborate with industry and regulatory bodies to adopt safer and more sustainable practices.
While large “super major” corporations, including those in the oil and gas sector, typically have many of the required safety practices in place, smaller businesses need more time to establish adequate resources and expertise to identify and handle chemical hazards effectively.
These organizations typically need to:
- Build process-centered safety management systems from the ground up.
- Train existing staff while maintaining operations.
- Absorb compliance costs across multiple budget cycles.
- Develop expertise in areas where they currently have significant knowledge gaps.
Common challenges facing smaller businesses, specifically when it comes to chemical hazard management, include:
- Limited internal expertise in process safety management.
- Insufficient understanding of fundamental chemical processes hazards and reaction kinetics.
- Inadequate control systems and safety procedures.
- Incomplete documentation of risks and mitigation strategies.
- Budget constraints affecting access to necessary expertise and control techniques.
Perhaps most dangerous is the false sense of security that can develop in organizations that have operated for years without experiencing major incidents. This complacency often masks serious underlying risks that could lead to catastrophic events.
The Safer Communities by Chemical Accident Prevention Rule requires these organizations to gain a deeper understanding of the potential risk operations may pose and the relevant best practices that may be needed to manage those risks responsibly.
A different action plan
For small and mid-sized organizations, achieving compliance with the revised rule requires a structured approach:
1. Assess current status: Conduct a thorough evaluation of existing safety systems and identify gaps in understanding and documentation.
2. Build core competencies: Invest in training and education to ensure staff understand the chemistry and processes they're handling.
3. Develop thorough documentation: Create meaningful safety procedures and risk assessments that truly address potential hazards.
4. Implement controls: Put in place appropriate safety systems, interlocks, and monitoring procedures.
5. Establish partnerships: Connect with industry experts and regulatory bodies for guidance and support.
The RMP rule revision marks a significant shift in chemical safety requirements for small and mid-sized organizations. While compliance may require substantial effort and resources, the result will be safer, more responsible operations that better protect both people and business interests.
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