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ARTICLE · 20 MARCH 2025

RMP Rulemaking Redux

The U.S. Environmental Protection Agency's (EPA) Risk Management Program (RMP) regulations, 40 C.F.R. Part 68, appear to be headed back to rulemaking.

United StatesEmployment and HR

The U.S. Environmental Protection Agency's (EPA) Risk Management Program (RMP) regulations, 40 C.F.R. Part 68, appear to be headed back to rulemaking. These much-debated provisions have been amended, rescinded, and reinstated. EPA will now reassess them, according to a recent EPA filing in the D.C. Circuit and an EPA statement. This reassessment is one of 31 actions EPA plans to undertake according to Administrator Lee Zeldin's March 12 announcement. EPA expects to publish a final rule in late 2026. Companies subject to RMP should stay alert for developments.

To get a fuller picture of what's going on, this alert provides a brief history lesson on RMP rulemaking.

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