With the possibility that the EPA and policymakers could make updates to the Risk Management Plan (RMP) program, there are three things we encourage them to keep in mind: 1. RMP is working as intended and keeping people safe. 2. Any changes to RMP must be evidence-based and actionable. 3. Using RMP to zero in on hydrofluoric acid (HF) alkylation at refineries could have major impacts on U.S. fuel supplies.
The U.S. petrochemical industry has a crucial and enduring role to play in meeting the needs of a growing world population while simultaneously fulfilling the imperative to produce petrochemicals in a sustainable and clean manner.
EPA’s existing Risk Management Plan (RMP) is doing what it was designed to do: drive continual safety improvements across workplaces to keep industry employees, contractors, facility neighbors and local environments safe. Any changes to a regulation as effective as the RMP need to be solidly evidence-based. Unfortunately, today’s proposal is filled with costly and misinformed changes, with little-to-no data to back them up. In fact, many of the proposed changes will adversely impact the safety and security missions of refining and petrochemical sites. AFPM looks forward to providing detailed comments on this proposal.
Because of the extensive safety and mitigation steps refiners take wherever hydrofluoric acid (HF) alkylation is concerned, the risks from this process pale in comparison to those we assume every day when we engage in routine activities like riding a bike, driving a car and playing with pets.
Our members continuously look for opportunities to enhance safety and recognize that an effective way to improve process safety performance throughout the industry is to learn from one other. Advancing Process Safety is a collection of programs that provide the industry with more frequent and effective opportunities to share experiences and knowledge.
AFPM collects occupational injury and illness data from all regular member refining and petrochemical sites in the U.S. annually. The information collected is from the OSHA 300A Summary Log for both company employees and contractors (contractor aggregate). This data is used to compile the AFPM Survey of Occupational Injuries & Illnesses (I&I Survey). Sites that submit data may be eligible for AFPM Safety Awards.
WASHINGTON, D.C. – The American Fuel & Petrochemical Manufacturers (AFPM) filed comments on the U.S. Environmental Protection Agency’s proposed amendments to the Risk Management Program (RMP) of the Clean Air Act asking it to withdraw the proposal.
