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Facility Process Safety Issue Page

Risk Management Program | Process Safety Management Standard | Pollution and Waste Management

Facility Process Safety Issue In the Chemical Distribution Industry

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NACD members pride themselves on the safety of their facilities. Each distributor member and chemical handler affiliate is required to participate in NACD’s Responsible Distribution® program, a mandatory third-party verified environmental, health, safety & security program through which companies demonstrate their commitment to continuous performance improvement in every phase of chemical storage, handling, transportation, and disposal. NACD supports regulatory safety policies that are risk-based, clear, and consistent.

For more information on specific facility process safety policies, please explore the topics below and browse NACD’s resource database. For the latest actions in these areas, follow us on Twitter and visit our Newsroom.

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Risk Management Program

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Section 112 (r)(7) of the Clean Air Act requires each facility that has specified quantities of certain chemicals to create and maintain a Risk Management Plan (RMP) to include a worst-case release scenario, five-year accident history, and emergency response plans. Covered facilities must submit RMPs to the U.S. Environmental Protection Agency (EPA) every five years or as changes occur and must coordinate with local response organizations. The EPA is working on proposed amendments to the RMP rules that would impose new requirements on facilities and attempt to address environmental justice and climate change. NACD is concerned about any changes to the RMP rules that would add needless complexity and distract from the core objective of preventing chemical accidents. The current regulations are comprehensive and robust and have proven highly effective in preventing chemical accidents when followed and enforced.

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Process Safety Management Standard

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The U.S. Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) is complementary to the U.S. Environmental Protection Agency’s Risk Management Program (RMP). Where the RMP is focused on preventing releases that would impact surrounding communities, PSM is focused on protecting workers within facilities. OSHA is considering amendments to the PSM standard that would expand the rule’s requirements and potentially subject more facilities to the rule. NACD is concerned about any changes to the PSM standard that would impose excessive new requirements. The current PSM rules are comprehensive and robust and have proven highly effective in protecting workers from harm caused by chemical accidents when followed and enforced.

Featured Resources

  • Understanding EPA’s Risk Management Plan and OSHA’s Process Safety Management Standard – January 2019

 

Pollution and Waste Management

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NACD recognizes the need for regulatory programs such as the Resource Conservation and Recovery Act and the Spill Prevention Control and Countermeasures rules to manage and reduce the pollution and waste emitted from facilities. It is imperative that pollution and waste are disposed of properly. As the U.S. Environmental Protection Agency and other agencies promulgate rulemakings related to pollution and waste management, NACD urges them to collaborate with affected industries to ensure the requirements are risk-based, clear, and practical. NACD welcomes the opportunity to work with regulators to find solutions that make sense for communities, the environment, and industry.

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For further questions about NACD’s Facility Process Issue Page, please contact Nicholas Breslin, Manager of Regulatory Affairs at nbreslin@nacd.com.