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Today's RMP Requirements: Impacts of the DC Circuit Court Decision on your Immediate and Long-term RMP Compliance

On Friday September 21, 2018, the DC Circuit Court heard both the petitioner’s joint motion for, and respondent’s opposition to, the expedited issuance of the RMP Rule Delay vacate, and the Court granted the petitioners motion. Thus, effective September 21, 2018, the RMP Final Rules (January 2017 version) are in effect and immediately triggered requirements to:

  • Review Incident Investigation findings in your Hazard Review/PHA
  • Include "supervisor" roles for covered process SOP training (initial & refresher)
  • Ensure incident investigations include near miss and destroyed processes
  • Include schedule to address recommendations in incident investigations
  • Ensure compliance audits address each covered process (not just a matrix approach)
  • All of the above were removed in the proposed Reconsideration Rule
While the court decision does not take the proposed RMP Reconsideration rule off the table, the January 2017 RMP rules will be in effect until the RMP Reconsideration rules are finalized. Significant additional changes will be effective if the Reconsideration Rule is not finalized before March 2021.

Join Trinity Consultants for a webinar covering the impacts of this court decision including what steps your facility should take (and when) to be in compliance with the RMP Final Rules (January 2017 version).  Trinity will also provide an overview of the proposed RMP Reconsideration Rule requirements so that your facility can plan the timing and resources to meet your RMP compliance obligations. 

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