Ask, Wait, and See
For over two decades we have developed and implemented some of the finest PSM/RMP programs across the country. Last time we checked there were over 7,500 locations that had RMP due to over 10,000 lbs of ammonia. There were only 14,500 location in the same time period that had submitted RMPs for the 140+ chemicals. GCAP has always said over half the PSM/RMP in the country is Ammonia, and large percentage of that is Ammonia Refrigeration. Obama’s executive order and mandated the re-write of PSM/RMP is all something of anticipation the last calendar year. December 2016 the anticipation ended for at least EPA’s expectations.
The ammonia refrigeration industry has just sent a letter to congress last week to apply the Congressional Review Act (CRA) to the Environmental Protection Agency’s new rule amending its Risk Management Program (RMP) according to this article on ammonia21.com written my Michael Garry. With over 21 differenct industry associations including IIAR and GCCA in agreeement asking to vacate the new final rule of EPA. If the House of Representatives and the Senate act on the request within 60 legislative days – giving it until about late March/early April – and President Trump lends his signature, then changes made to the RMP in the final rule would be vacated.
Keep your fingers crossed, we may have not much change at all.