In February 2026, the US Environmental Protection Agency (EPA) released a proposed rule titled the “Common Sense Approach to Chemical Accident Prevention.” If finalized, this rule would roll back many of the critical safety provisions introduced in the 2024 Risk Management Program (RMP) Final Rule—provisions that were designed to protect workers, communities, and the environment from catastrophic chemical incidents.
While the name of the proposal may sound reasonable, the implications are anything but.
What’s changing and why it matters
The proposed rule would largely return the RMP regulation to its pre-2024 state. Among the most significant rollbacks are:
- Eliminating the requirement for conducting Safer Technologies and Alternatives Analysis (STAA) for existing Program 3 processes and for implementing mitigation measures to reduce risk.
- Altering or completely removing automatic triggers for third-party compliance audits following one or more RMP reportable incidents.
- Removing requirements to evaluate natural hazard and power-loss scenarios in hazard reviews and process hazard analyses (PHAs).
- Rescinding provisions that empowered employees to participate in safety-related decision-making and to report safety concerns.
- Curtailing public access to chemical hazard information and community notification systems.
The rationale behind these proposed revisions? Reduce regulatory burden, eliminate duplication, and promote economic growth.
What you should do now
The proposed rule is open for public comment through April 10, 2026. Organizations should take the time to review and understand how it may impact their operations. But in the meantime, until the proposed rule is finalized, stay the course on your 2024 RMP compliance efforts. The current rule is still in effect, and the 2027 deadlines for inclusive, realistic emergency response drills, enhanced PHAs and employee participation efforts, third-party compliance audits, and safer technology evaluations remain legally binding.
Use this moment to:
- Reaffirm your commitment to safety beyond compliance.
- Revisit your STAA and PHA processes: Could they use an update? Are they comprehensive enough?
- Engage your workforce in meaningful safety conversations.
- Strengthen your emergency response coordination with local agencies and communities.
When the next incident happens, and history tells us it will, your preparation will matter more than your paperwork. Let’s not let “common sense” become a shield for complacency. Let’s lead with purpose; protect our people, the community, and the environment; and build systems that stand the test of time.
