EPA Proposes Major Changes to Clean Air Act Risk Management Program Requirements

EPA Proposes Major Changes to Clean Air Act Risk Management Program Requirements
March 12, 2026 Edge Engineering

The U.S. Environmental Protection Agency (EPA) has issued a proposed rule that could significantly modify Clean Air Act Risk Management Program (RMP) requirements for facilities that handle listed toxics and flammable substances.

The proposal revisits elements of the 2024 RMP rule, which introduced new prevention and reporting requirements for regulated facilities. Following feedback from industry stakeholders about implementation challenges and overlapping regulatory obligations, EPA is now considering revisions intended to improve regulatory efficiency while maintaining accident prevention goals.

These proposed revisions signal EPA’s effort to reconsider several of the most debated provisions introduced in the 2024 RMP rule while maintaining the program’s core focus on chemical accident prevention.

Overview of the Proposed Changes

The proposed rule focuses on refining accident prevention requirements and improving consistency between EPA’s RMP framework and the Occupational Safety and Health Administration’s Process Safety Management (PSM) regulations.

The proposed adjustments include updates to requirements related to:

  • Safer Technology and Alternatives Analysis (STAA) evaluations for certain processes
  • Third-party compliance audits that were introduced in the 2024 rulemaking
  • Public access to RMP information, including use of an EPA-managed data tool
  • Employee participation provisions to better align with OSHA PSM requirements

EPA is also evaluating revisions affecting several additional program elements, including emergency response coordination, natural hazard considerations, process safety documentation, and incident investigation procedures.

Potential Impacts for Regulated Facilities

Facilities subject to the Risk Management Program should review the proposed revisions closely to understand how compliance expectations may evolve. Proposed changes affecting accident prevention analyses, audit requirements, and public information reporting could influence how facilities structure environmental compliance and process safety programs.

EPA estimates the proposed revisions could generate meaningful cost savings for regulated facilities while maintaining the program’s core objective of preventing chemical accidents. The agency is accepting public comments on the proposal through April 10, 2026.

Organizations evaluating the proposed revisions should begin considering how potential changes could affect their compliance programs and operational planning. Arijit Pakrasi, Ph.D., P.E., at EDGE Engineering & Science, works with clients to understand and comply with RMP requirements.  He also works with clients to evaluate proposed rulemakings and assess how regulatory changes may influence facility operations, compliance planning, and long-term risk management.  Having followed developments of the RMP rule and industry stakeholder concerns, EDGE is positioned to help organizations prepare and submit comments on the proposed rule.

For #FurtherInsight on the proposed EPA changes to the Risk Management Program and how they may affect regulated facilities, contact EDGE Engineering & Science.

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