Background - Privacy & Cybersecurity

Privacy & Cybersecurity


Got Chemicals? The State of Play on Chemical Security Regulations

December 17, 2014 • Webinar

Starts: 2:00 PM (EST)
Ends: 3:30 PM (EST)

Recent chemical facility incidents in the United States prompted President Obama to issue Executive Order 13650 in August 2013 – “Improving Chemical Facility Safety and Security.” The Order directed federal agencies to consider enhancements to their respective chemical safety and security programs. In response, EPA, DHS, and OSHA are pursuing regulatory changes that could have far-reaching impacts not only on chemical companies but also on a broad array of entities that store, use, possess, or handle high-risk chemicals. This webinar will provide an update on these important administrative proceedings and a preview of what may be in store for affected stakeholders, including utilities, hospitals, universities, manufacturers, oil and gas producers, and pipelines.

This webinar will examine:
  • EPA’s Request for Information (RFI) on potential revisions to its Risk Management Program (RMP). The EPA solicited information on updating its list of regulated chemicals, as well as specific regulatory elements and process safety management approaches, including the use of safer technologies, the “safety case” regulatory model, and many of the same proposals on which OSHA has solicited information concerning its  process safety management standard.
  • DHS’s Advanced Notice of Proposed Rulemaking (ANPRM) seeking comments on modifications to its Chemical Facility Anti-Terrorism Standards (CFATS). DHS is reviewing stakeholder comments on a range of CFATS issues, including exclusions, streamlining, applicable chemicals, and performance standards. Given the applicability of the CFATS rule across many sectors, a rulemaking of the sort contemplated by the ANPRM could have major operational and economic effects.
  • OSHA’s RFI on updates to its process safety management (PSM) standard. OSHA is considering numerous PSM changes, and to that end solicited information on updating its list of highly hazardous chemicals, applying PSM requirements to upstream oil and gas drilling, servicing, and production, requiring third -party audits, and managing organizational changes as part of PSM.

We hope that you can join us for this timely and lively discussion on the state of play on a trifecta of chemical security regulations and updates.

Please click here for a copy of the presentation.

Crowell & Moring Participant(s):
Warren Lehrenbaum
Partner – Washington, D.C.
Phone: +1 202.624.2755
Daniel W. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2621
Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615