EPA Proposes Major Changes to the RMP Rule | Blog No. 115

In February 2026, the U.S. Environmental Protection Agency (EPA) introduced a proposed rule that would significantly modify the Risk Management Program (RMP) regulations under the Clean Air Act. The proposal, referred to as the “Common Sense Approach to Chemical Accident Prevention,” would reverse or scale back many of the requirements established in the 2024 Safer Communities by Chemical Accident Prevention (SCCAP) rule.

If finalized, the proposal could substantially change how facilities manage RMP compliance. Public comments on the proposal are being accepted through April 10, 2026, and EPA has scheduled a virtual public hearing on March 10, 2026, as part of the rulemaking process.

Background and Purpose of the Proposal

RMP regulations have changed multiple times over the past decade as administrations have taken different approaches to chemical safety regulation. In 2017, the EPA issued amendments that expanded accident prevention, emergency response, and public disclosure requirements. Many of those provisions were later rescinded or modified in 2019. The 2024 SCCAP rule restored many of the earlier concepts and introduced additional compliance obligations.

The 2026 proposal would again shift the direction of the rule by removing or modifying several SCCAP provisions and moving portions of the program closer to the framework that existed prior to the 2024 changes.

EPA states that the proposed revisions are intended to improve chemical process safety while reducing unnecessary regulatory burden. According to the agency, the proposal focuses on reducing overlapping requirements between EPA’s RMP rule and OSHA’s Process Safety Management (PSM) standard, eliminating provisions that may not have clear evidence of reducing accidental releases, simplifying compliance for regulated facilities, and focusing regulatory requirements on areas supported by accident and compliance data.

EPA also noted that RMP-reportable accident rates have generally declined over the past decade, suggesting that existing regulatory frameworks may already be contributing to improved safety performance.

Major Proposed Changes to the RMP Rule

The proposed rule would revise several key components of the SCCAP regulation.

One of the most significant changes involves Safer Technology and Alternatives Analysis (STAA). The SCCAP rule required certain Program 3 facilities in specific industry sectors to evaluate and implement inherently safer technologies or designs. Under the new proposal, the implementation requirements for existing facilities would largely be removed. STAA evaluations would instead apply primarily to new Program 3 processes, including processes added to existing facilities after the rule becomes effective. When these evaluations are conducted, facilities would still consider inherently safer technologies or designs, passive safeguards, active safeguards, and procedural measures.

The proposal also addresses third-party compliance audits. EPA is considering two alternative approaches. One option would eliminate the third-party audit requirement entirely. The second option would require third-party audits only for facilities that experience two RMP-reportable accidents within a five-year period. Under that option, the requirement would begin three years after the final rule is published and would sunset after ten years.

Changes are also proposed for public access to facility hazard information. The SCCAP rule expanded requirements for facilities to provide chemical hazard information to individuals living or working near the facility upon request. The new proposal would remove those direct disclosure requirements and instead rely on EPA’s RMP Public Data Tool, which provides general information such as regulated substances present, accident history, and emergency response contact information. EPA also proposes limiting the tool’s search capabilities and removing its mapping function.

Several employee participation provisions introduced by the SCCAP rule would also be removed. These include requirements related to consulting employees on certain findings from process hazard analyses, compliance audits, and incident investigations, as well as additional stop-work authority provisions. Facilities would still be required to maintain a written employee participation plan and provide annual notice of that plan.

The proposal would also remove certain provisions related to natural hazards and power loss evaluations that were added in the 2024 rule. Instead of specific regulatory language emphasizing these hazards, facilities would return to the previous approach, where such risks are considered within general hazard reviews and process hazard analyses.

Another change involves documentation requirements for declined safety recommendations. The SCCAP rule required facilities to formally document and report certain recommendations that were considered but not implemented. The proposed rule would remove several of these reporting obligations.

EPA also proposes changes related to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). The proposal would remove the requirement for Program 3 PHAs to perform a gap analysis comparing facility practices to applicable codes and standards. However, the rule would retain the requirement that process safety information be kept up to date, and facilities would still be expected to design and maintain systems consistent with applicable engineering practices.

The proposal would also simplify community notification and emergency response coordination requirements. Facilities would still be responsible for coordinating with local emergency response organizations regarding notification procedures during accidental releases. However, several documentation requirements would be removed and replaced with limited reporting elements included in the RMP submission.

What Happens Next

Because this rule is still in the proposal stage, none of these changes are final. The next steps include the public comment period, the scheduled public hearing, EPA’s review of submitted comments, and eventual publication of a final rule.

EPA has also indicated that certain SCCAP compliance dates, including some provisions scheduled for May 2027, may remain unchanged even as other parts of the rule are reconsidered. Additional revisions may occur before a final rule is issued, and legal challenges are possible given the scale of the proposed regulatory shift.

What Facilities Should Do Now

Facilities subject to RMP requirements should review the proposed rule and monitor the rulemaking process closely. Many SCCAP provisions may ultimately be rescinded or modified, but until a final rule is issued, facilities should continue planning around current regulatory requirements and compliance deadlines.

Organizations may also consider submitting comments to EPA if specific provisions in the proposal would significantly impact operations or compliance programs.

Final Thoughts

The proposed Common Sense Approach to Chemical Accident Prevention rule represents a significant potential shift in EPA’s Risk Management Program regulations. If finalized largely as proposed, the rule would remove several requirements introduced in the 2024

SCCAP rule, simplify certain compliance obligations, and move portions of the RMP program closer to alignment with OSHA’s PSM framework.

Because the rulemaking process is still ongoing, facilities should continue monitoring developments and remain prepared to adjust their compliance strategies as the regulatory landscape evolves.

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