Law360, New York (May 6, 2015, 12:09 PM EDT) -- Facilities that use certain quantities of “extremely hazardous substances” are required by Section 112(r) of the Clean Air Act to maintain detailed risk management plans (RMPs) and comply with related U.S. Environmental Protection Agency and U.S. Occupational Safety and Health Administration accident prevention regulations.
Increased enforcement by the EPA in the wake of recent high visibility chemical accidents has enhanced the risk of RMP inspections, referred to as audits, by the agency and delegated states. The numerous and detailed requirements of the program and “multipliers” in the EPA penalty policy can result in substantial penalties for seemingly minor infractions. The enhanced...
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