EPA and Chemical Safety Inspections: Employees Asked to Participate

EPA seeks employee participation in chemical safety inspections.

Breaking News:  The U.S. Environmental Protection Agency (EPA) has released interim guidance that aspires to provide greater transparency in the agency’s chemical safety inspections process.  Under the interim guidance, EPA inspectors will offer employees and employee representatives the opportunity to participate in chemical safety inspections.

EPA will also request that state and local agencies adopt similar procedures under the risk management program.

The Risk Management Plan Rule (RMP Rule) requires companies of all sizes that use certain flammable and toxic substances to develop a Risk Management Program.  The program includes a(n):

1. Hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases
2. Prevention program that includes safety precautions and maintenance, monitoring, and employee training measures
3. Emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g the fire department) should an accident occur

The Risk Management Program overall is about reducing chemical risk at the local level.  Chemical information -- what is housed where and what the properties and hazards are -- helps local fire, police, and emergency response personnel (who must prepare for and respond to chemical accidents).  This level of chemical information is very useful in general to citizens in understanding the chemical hazards in communities.

Under the Clean Air Act, the Chemical Accident Prevention Provisions require facilities that produce, handle, process, distribute, or store certain chemicals to develop a Risk Management Program, prepare a risk management plan, and submit the plan to EPA. EPA expects to issue final guidance on participation of employees and employee representative in RMP inspections later this year.

If you have questions or concerns, contact us for tricks and solutions.  Start here - Information Week article on how electronic systems tend to be best for managing hazardous materials.  See also article on material disclosure best practices - but mind you, that link takes you to e-Magazine version of Chem.Info Magazine and you have to turn to Page 8.  Still - there are 20 Best Practices listed and its worth reading.  To get in touch with EPA, the contact for this subject is Dale Kemery (try kemery dot dale at epa dot gov).  Good luck; please write a note if you find anything you think others could benefit from knowing.

Towards increased transparency of chemicals

EPA believes that involvement of employees and employee representatives in inspections is more effective in terms of inspection results and better protects workers and the adjacent communities.   EPA anticipates that making the RMPs available to the public stimulates communication between industry and the public to improve accident prevention and emergency response practices at the local level.

It seems to so far -- as you can see, we jumped to blog about it as soon as the announcement posted!  It's definitely buzz-worthy news.  Stay alert; stay tuned.