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Virtual SEER 28th Fall Conference: The Clean Air Act’s Risk Management Program: A Critical Regulatory Tool or Classic Administrative Overreach? [CC]
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Virtual SEER 28th Fall Conference: The Clean Air Act’s Risk Management Program: A Critical Regulatory Tool or Classic Administrative Overreach? [CC]
Join our panel for a discussion of the EPA Risk Management Program and trends in enforcement and compliance strategies.
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Closed Captioned.
In response to alarming domestic and international chemical accidents, Congress enacted Section 112(r) within the 1990 Clean Air Act Amendments. Section 112(r) required EPA to develop regulations preventing and minimizing accidental releases of various "extremely hazardous substances," eventually becoming the Risk Management Program or RMP. While some RMP elements resemble classic command concepts, the more onerous require compliance with performance-based industry standards not incorporated by reference, but through general concepts like "Recognized and Generally Accepted Good Engineering Practices." The 1990 Amendments also added a General Duty Clause, requiring facilities to "identify hazards”\" but lacking any implementing framework. Enforcement of RMP was elevated to a National Enforcement/Compliance Initiative under both the Obama and Trump Administrations with actions routinely garnering high-dollar headlines across the country. This panel will discuss recent regulatory changes, compliance strategies, enforcement trends, RMP’s relationship to OSHA standards, and the enduring tension between regulations and corresponding guidance, providing attendees with a strong foundation to handle the most challenging RMP matter.
Speakers
Steven Cook, Deputy Assistant Administrator, Office of Land and Emergency Management, U.S. Environmental Protection Agency, Washington, DC
Julie Domike, Babst Calland, Washington, DC
Eric Tilles, Deputy General Counsel; Manager, Ethics and Compliance, Arkema, King of Prussia, PA
Moderator
Robert Bartlett, Co-Founder, Principal Consultant, Amplify Process Safety, LLC, Houston, TX
Product Details
Moderators
Product Code
NR2010SFCW15OLC
Duration
60
Publication Date
10/23/2020 12:00:00 AM
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