The Environmental Protection Agency recently announced a final rule rescinding major amendments to the Clean Air Act §112(r) Risk Management Program (RMP) regulations that were promulgated at the end of the Obama Administration in 2017. The 2017 revisions were promulgated partially in response to a 2013 explosion at a fertilizer company in West Texas, which caused 15 fatalities and injured more than 260 people, and had yet to go fully into effect due to administrative and court challenges and because most of the compliance deadlines had not yet been triggered.

The provisions of the 2017 rule that have been rescinded include requirements:

  • To assess theoretically safer technology and alternative analysis of risk management measures targeting process hazards;
  • For third-party compliance audits after a reportable RMP accident; and
  • To perform root cause analyses after RMP accidents or near misses.

Click here for the full GT Alert, EPA’s Final Risk Management Program Reconsideration Rule More In-Step with OSHA’s Process Safety Management Standards.

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Photo of Christopher Bell Christopher Bell

Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes…

Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes internal investigations, responding to grand jury investigations and agency information requests, and negotiating consent, probation, and debarment agreements. He is currently the EPA Independent Monitor overseeing the nation’s largest investor-owned energy company’s compliance with complex debarment and probation agreements arising from the resolution of a criminal enforcement case brought under the Clean Water Act.

Chris assists buyers, sellers, investors and financial institutions on the environmental aspects of transactions, including conducting due diligence, negotiating the environmental provisions of transactional documents, and identifying and executing insurance-based risk management opportunities. His transactional experience has included upstream, midstream and downstream energy projects, alternative energy projects, and transactions in the manufacturing, logistics, consumer products and chemicals sectors.

He helps clients evaluate and implement compliance and ethics programs (e.g., under the Sentencing Guidelines), and environmental, health and safety management systems (including based on ISO 14001). Chris advises clients on sustainable development, climate change, product and chemical stewardship and regulation, and value chain management. He recently served on an independent committee advising the senior management of a Fortune 50 company on its global sustainability strategy and reporting.

Photo of Michael Taylor ‡ Michael Taylor ‡

Michael Taylor is Chair of the Greenberg Traurig OSHA Practice group. Michael focuses his nationwide practice exclusively on representing employers regarding workplace safety and health matters. Over the last two decades, Michael has represented hundreds of employers during federal and state workplace safety…

Michael Taylor is Chair of the Greenberg Traurig OSHA Practice group. Michael focuses his nationwide practice exclusively on representing employers regarding workplace safety and health matters. Over the last two decades, Michael has represented hundreds of employers during federal and state workplace safety and health litigation, many of which involved a significant injury, fatality, fire, explosion, or catastrophic release of a highly hazardous substance in the workplace. Michael also provides federal and state workplace safety and health compliance counseling, inspection counseling, whistleblower representation, and due diligence reviews for clients. Michael also represents employers regarding Chemical Safety Board investigations in response to a significant fire, explosion, or catastrophic release of a highly hazardous substance in the workplace. Michael has significant experience in the oil, gas, electric utility, grain, construction, and chemical manufacturing industries.

Michael previously served as General Counsel to the federal Occupational Safety and Health Review Commission, the agency in charge of adjudicating workplace safety and health disputes between federal OSHA and the regulated community.

Michael is the Founder and Host of the Greenberg Traurig Workplace Safety Review Podcast, where he interviews influential environmental, health, and safety professionals across the country regarding timely and important topics in the environmental, health and safety world. Recent guests have included Douglas Parker, Assistant Secretary of Labor for Occupational Safety and Health in the Biden Administration; Deborah Harris, Chief of the U.S. Department of Justice Environmental Crimes Section; John Howard, Director of NIOSH and Administrator of the World Trade Center Health Program in the U.S. Department of Health and Human Service; Nadine Mancini, General Counsel of the federal Occupational Safety and Health Review Commission; and Richard Fairfax, former Deputy Assistant Secretary of Labor for federal OSHA.

In 2020, Michael was recognized as a “Labor & Employment Star” in the Benchmark Litigation Labor & Employment rankings, and, in 2013, EHS Today named Michael as one of the Top 50 People Who Most Influenced Environmental, Health, and Safety.

 Admitted in the District of Columbia. Not admitted in Virginia. Practice in Virginia limited to federal OSHA and proceedings before federal agencies.

Genus Heidary

Genus Heidary focuses much of her practice on environmental, health, and safety-related matters, providing both proactive compliance counseling, as well as strategic advocacy at times of enforcement litigation. She has comprehensive experience counseling clients through major industrial accidents, workplace fatalities, agency inspections, and

Genus Heidary focuses much of her practice on environmental, health, and safety-related matters, providing both proactive compliance counseling, as well as strategic advocacy at times of enforcement litigation. She has comprehensive experience counseling clients through major industrial accidents, workplace fatalities, agency inspections, and crisis management at times of potential toxic releases. Genus works with technical experts and auditors, providing compliance counseling in relation to the development and improvement of environmental, health, and safety programs. Much of this work requires her to take the lead on internal investigations to evaluate litigation risk, as well as compliance readiness. Her portfolio also includes due diligence risk assessments of commercial deal work.

With a background in public policy and years of courtroom experience as a litigator, Genus also represents clients from a broad array of industries – including manufacturing, health care, technology, energy, real estate, and financial services – in challenges to agency rule-makings, supervisory investigations, complex litigation, and class action lawsuits, as well as civil and criminal enforcement actions brought by federal and state regulatory agencies, state attorneys general, and the Department of Justice (DOJ).  Such experience has allowed her to represent clients before agencies including the Department of Labor (DOL), Environmental Protection Agency (EPA), Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Trade Commission (FTC), and the Federal Reserve Board, or related state agencies.