Almost all my new posts are on RCE Chill. I only post things here that are controversial personal opinions.
If you are looking for information on the OSPSM project, an Open-Source resource for PSM and Safety Templates please contact me.
You can contact me via email. If you need immediate assistance call me at 570-437-0660.
Often, compliance and safety go hand-in-hand. This leads us to believe they are the same thing. Occasionally they are not; and when that’s the case, it is our duty to place SAFETY above Compliance.
Relief Piping Termination – A worked example
Here’s a picture of a relief termination found in the field…
Notice that the relief termination is cut at a 45 degree angle with the opening facing down. As shown below, this is one of the many termination methods described in the IIAR’s Piping Handbook
Our RAGAGEP is IIAR 2-2014a which states:
IIAR 2 2014a 15.5.1.5* The termination of the discharge shall be directed upward and arranged to avoid spraying ammonia on persons in the vicinity.
Note: In the informative appendix “IIAR 2 2014a A.15.5.1.5 The termination of discharge is considered the final several feet of the relief piping. The vent end point of relief piping may include a design to prevent rain and snow from entering. Many designs provide a method to prevent rain and snow from entering. The design at the vent end point may be a “tee” diffuser…”
I’m certainly not the first to notice this issue. A few years ago, Bryan Haywood of SAFTENG.NET wrote a small article about it. Others have argued that this is a compliant arrangement.
Reasonable people can disagree and often PSM/RMP is about making a defensible case. To me, this relief termination is NOT compliant with IIAR 2 2014a 15.5.1.5 because the release will be directed DOWNWARD at a 45 degree angle directly at a roof where we know we will occasionally have service personnel.
Regardless of where you come down on the compliance issue, being compliant does not mean you are safe.
To put it another way, the danger posed by NH3 being released towards the roof and service personnel doesn’t go away even if you believe the arrangement shown above is compliant with IIAR 2 2014a 15.5.1.5.
You’d still have to analyze this hazard and attempt to control it.
Note: You could easily modify this arrangement like the picture below to be both compliant AND safe.
By adding a small elbow they’ve directed the flow upwards and arranged to avoid spraying ammonia on persons in the vicinity
The IIAR has announced a 3rd Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems. This brings some interesting changes to IIAR 2 . Two of these proposed changes are :
For more information, check out the announcement (with links) below:
A third (3rd) public review of draft standard BSR/IIAR 2-2014 Addendum A, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.
BSR/IIAR 2-2014, Addendum A specifies the minimum safety criteria for design of closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of ammonia refrigerating system(s) and basic ammonia refrigerating practices and principles. This standard is intended for those who develop, define, implement and/or review the design of ammonia refrigeration systems. This standard shall apply only to closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It supplements existing general refrigeration standards issued by IIAR and other organizations such as ASHRAE, ASME, and ANSI. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes).
IIAR has designated the revised standard as BSR/IIAR 2-2014, Addendum A. Upon approval by the ANSI Board of Standards Review, the standard will receive a different name that reflects this approval date.
We invite you to participate in the third (3rd) public review of BSR/IIAR 2-2014, Addendum A. IIAR will use the American National Standards Institute (ANSI) procedures to develop evidence of consensus among affected parties. ANSI’s role in the revision process is to establish and enforce standards of openness, balance, due process and harmonization with other American and International Standards. IIAR is the ANSI-accredited standards developer for BSR/IIAR 2-2014, Addendum A, and is responsible for the technical content of the standard.
This site includes links to the following attachments:
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The 30-day public review period will be from October 5, 2018 to November 4, 2018. Comments are due no later than November 4, 2018.
Thank you for your interest in the public review of BSR/IIAR 2-2014, Addendum A, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems.
EPA retains authority under Section 7412(r)(7) to substantively amend the programmatic requirements of the Chemical Disaster Rule, and pursuant to that authority, revise its effective and compliance dates, subject to arbitrary and capricious review.
. . . the agency must examine the relevant data and articulate a satisfactory explanation for its action including a rational explanation of the facts found and the choice made.” When an agency reverses itself, it “must show that there are good reasons for the new policy,” but it need not show that “the reasons for the new policy are better than the reasons for the old one.” However, if the “new policy rests upon factual findings that contradict those which underlay its prior policy,” it must provide “a reasoned explanation . . . for disregarding facts and circumstances that underlay or were engendered by the prior policy.”
What does it mean?
The district court said they could have made a new rule which struck down the Obama-era updated rule, but they can’t delay that Obama-era rule longer than the 90 days in the CAA statute. So, the EPA has a few options here:
My guess is that it’s a combination of the first 3 options.
You can read the court’s ruling in its entirety online.
The following is my opinion, and you are welcome to skip over it: I have a hobby of reading court rulings and was a bit surprised that the wording the court used. In my opinion, they make a strong case on the law, but have really fluffed it up their ruling with a lot of dramatic language that’s unnecessary.
You almost get the impression they believe that the Obama-era updated rule is going to have a dramatic positive impact on the safety of the chemical industry. If implemented, I believe it will have a dramatic positive impact on the process safety consulting industry but might actually have a negative impact on process safety as it requires people to spend a LOT of time and money on things that haven’t been shown to significantly affect process safety.
Furthermore, there is very little evidence that the changes in the Obama-era updated rule would have prevented or significantly mitigated any of the accidents the court discusses. Just one example is West Texas, which the court discusses but the chemicals involved in the the explosion are not regulated under the RMP rule. The entirety of the updates seems to be more “process safety theatre” than an actual improvement to the regulation.
Process Safety managers are often buried under a torrent of Findings and Recommendations from PSM/RMP elements such as Employee Participation (EP), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), Incident Investigations (II), and Compliance Audits (CA).
In compliance audits over the past decade the single most likely deficiency I find is failing to properly “address” these Findings / Recommendations. Note: a Finding / Recommendation is considered “addressed” when you either accept & implement it, or justifiably delay the implementation while assuring safe operation. The most common problems are:
Let’s look at each of these and discuss how Process Safety manager typically fail, and what YOU can do to avoid common failures.
Failing to respond to a Finding / Recommendation
Failing to respond to known issues is all too common. There are many reasons this happens, but in my experience, here are the most common problems:
Not understanding the issue.
Solution: Ask questions about the reason for the Finding / Recommendation. Don’t let someone tell you that something has to be done a certain way without an adequate explanation. Many unnecessary Findings / Recommendations can be avoided or solved simply by asking the person making it to provide their actual reasons for it. This isn’t about feelings. Ask for the specific hazard, regulation, code, standard, etc. You can’t judge a Finding / Recommendation without understanding it, and neither can management. In the case of legitimate Findings / Recommendations, understanding the issues behind the Finding / Recommendation will help you gain momentum to address the problem.
Assuming the solution won’t be approved
Solution: Don’t prejudge. That isn’t your role. Your role as the Responsible Person is to bring these issues to the people that are in charge of the process. Ask the right questions and present the necessary information to management. THEY are responsible for their decisions after that. Your role is to document their responses and remind them if you haven’t received adequate direction on the disposition of the Finding / Recommendation.
Losing Track of the Finding / Recommendation
Solution: Implement a robust tracking method. Personally, I’ve always liked tracking sheets, but electronic software can work too. Whatever your method, you need a *system* to promptly address and resolve Findings / Recommendations. Once you’ve established this system, use it to set the agenda of your regularly scheduled Process Safety meetings. A tracking system should document:
Where the Finding / Recommendation came from.
Why the recommendation was made and the the actual text of the Finding / Recommendation.
When the Finding / Recommendation was made. When the Finding / Recommendation (and any interim measures) are to be completed by. When activities on it occur and, ultimately, when it is marked as fully addressed.
Who is Responsible for it.
What has been done, is being done, and is planned to be done.
Failing to document the Response
If you’ve implemented a system to track Findings / Recommendations, then this shouldn’t be an issue. Where most people fail here is not documenting what they are told. An example: you bring up a recommendation during a conversation with management and they give you an answer, but you don’t document that verbal answer in your tracking system. Even better, when you are given verbal answers to a Finding / Recommendation, either document that answer in the meeting notes or in a follow-up email to the person that gave you the verbal answer.
Even when you actually addressed the Finding / Recommendation, failing to document it can come back and bite you. I’ve witnessed a situation where a recommendation to paint a valve group was implemented but not documented. A few years later, during an OSHA inspection, the facility was cited for not documenting that they did the work – even though the CSHO agreed that the valve group appeared to have been painted. Remember, there are explicit requirements in the PSM rule that you document Finding / Recommendation resolutions: PHA e(5) “the resolution is documented; document what actions are to be taken…” Incident Investigation m(5) “…Resolutions and corrective actions shall be documented.” Compliance Audit o(4) “…determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.”
Assured Interim Safety or Interim Measures
When you receive a Finding / Recommendation, it’s best to work with the j(5) standard: “… correct deficiencies…before further use or in a safe and timely manner when necessary means are taken to assure safe operation.”
Put simply: Either shut it down or ensure it’s safe to operate while you are planning & implementing your response.
Let’s use the example of a valve group that has been identified as “rusty.”
First, we need to evaluate the condition of the valve station. Is it so bad that you don’t know if it’s safe? If so, shut it down until you can evaluate it further. Document this decision and the reasons for it.
Is it mild surface rust such that it just needs cleaning and a fresh coat of paint? Either clean and paint it right away or document why it’s safe to operate until when you plan on cleaning and painting it.
Bonus: What a flowchart of a SYSTEM for Finding / Recommendation resolution can look like:
The October 17th, 2017 Ammonia release in Fernie, BC resulted in three fatalities:
On October 16, 2017, the curling brine chiller at the Fernie Memorial Arena was put back into operation after a seasonal shutdown. During the shutdown and seasonal maintenance, ammonia had been detected in the curling brine system, indicating that the curling brine chiller was leaking… A total of three people were found deceased in the mechanical room: the director of leisure services, the refrigeration operator, and a refrigeration contractor mechanic.
Three people died in a completely avoidable incident. If you want to know the particulars of the incident, I’d recommend you go read the Incident Report itself. While we can’t go back in time and avoid this particular incident, we can extract some valuable lessons from it to prevent a similar incident in the future.
There’s a lot that went wrong, but we’re going to focus on a few key failures in Mechanical Integrity, Process Safety, and Release / Incident Response. We’ll briefly discuss each failure and provide ten opportunities for improving your current Process Safety system.
Note: While this incident occurred in Canada, which does not have robust Process Safety regulation, we’re going to provide our analysis as if it was a PSM/RMP plant. Even if this incident had occurred in the US, the total system inventory was estimated at less than 1,000 pounds, placing it in the General Duty category. Most operators of these General Duty systems do not choose to implement a PSM system – hopefully this incident will cause them to re-evaluate that choice.
Equipment Age and installation: In 2011, the facility received a recommendation from their mechanical contractor to replace the chiller due to its age. It had been in service for about 24 years and had a life expectancy of 20-25yrs. (At the time of failure the chiller was in service for approximately 31yrs.) The facility actually budgeted for this replacement, deferred it, and then dropped the idea altogether. The report (and appendices) detail this decision making and indicates that the people making these decisions didn’t understand the underlying safety issues or the possible repercussions of these decisions. In part this was due to management turnover – the people who received the initial recommendation no longer worked at the facility when those recommendations were due to be implemented. Additionally, post-release, it was determined that the failed coupling was not properly supported.
Possible PSM citations: 1910.119(d)(3)(ii) for not installing the coupling per the manufacturers recommendations. 1910.119(d)(3)(ii) for equipment operating outside manufacturer’s recommended lifespan. 1910.119(e)(1) for the PHA not analyzing the hazards associated with operating outside the manufacturer’s recommended lifespan. 1910.119(j)(5) for operating the equipment with a known (service life) deficiency without assuring safe operation. 1910.119(m)(5) for not addressing and resolving a recommendation. (if the recommendation was made due to an indication of NH3 in the brine)
Opportunity #1: When a piece of equipment has a stated service life, you need to either replace the equipment per the recommendation or support your decision to keep it in service with a suitable engineering rationale.
Opportunity #2: When operators & contractors make recommendations, they need to provide CLEAR and defensible reasons for those recommendations.
Opportunity #3: When recommendations are delayed, deferred, or not completed, the operators & contractors need to ensure that the decision makers understand the implications of their decisions.
Opportunity #4: A Pre-Startup Safety Review (PSSR) and ongoing MI tasks need to ensure that equipment is installed correctly and maintained in a safe manner / arrangement.
Signs of Failure and Deficiency Response: The facility detected NH3 in the brine (by scent) in April of 2017 and then followed it up with a lab test of the brine showing over 3,000ppm of NH3 in June. The facility decided to continue operating the chiller and “monitor” it. A second test in August showed an NH3 concentration near 2,000ppm. Again, the facility decided to keep “monitoring” the situation. The report indicated that the personnel performing the tests and receiving the results didn’t understand the safety implications of them. Even after receiving the tests showing the chiller had failed, the facility decided to keep operating it. According to the report, there was no evidence the facility understood the hazards associated with a leaking chiller.
Furthermore, due to a miscommunication, the contractor believed the facility had taken the chiller out-of-service and they were preparing a bid to replace the leaking unit. The contractor’s recommendation to “monitor” the unit was likely meant to monitor it to see if the valves were leaking by, but the facility interpreted it as a go-ahead to continue operating the defective chiller until it could be replaced as long as they “monitored” it.
The contractor had no policy or procedure in place to deal with a failed chiller outside the usual troubleshooting, repair and replace activities. The investigators concluded that none of the people involved with the decision to continue operating the chiller had training or qualifications involving condition/risk assessment.
Possible PSM citations: 1910.119(j)(5) for operating the equipment with a known (integrity) deficiency without assuring safe operation. 1910.119(m)(5) for not addressing and resolving a recommendation. 1910.119(g)(1)(i) for not training personnel of the hazards associated with a leaking chiller.
Opportunity #5: Personnel reviewing test results need to understand the meaning of the test results and the safety implication of those test results.
Opportunity #6: When test results are provided to decision-makers, these results need to provide adequate information so that the decision-makers understand them and their safety implications.
Opportunity #7: When contractors are called to deal with deficient equipment, they will almost always provide guidance / estimates on how to repair / replace the equipment, but facilities should demand a risk assessment on continued operation of the equipment if they intend to continue its operation while planning and preparing for the repair / replacement.
From Appendix V of the report: “In the majority of instances, owner/operators relied heavily on the refrigeration contractor’s assessment of the equipment and evaluation of the NH3 indication in the brine samples. The owner is accountable for the safe condition and operation of the equipment but in some instances, deferment to the refrigeration contractor’s assessment and recommendations for the equipment was observed.”
Opportunity #8: When a facility outsources maintenance work, they often erroneously think that they are outsourcing the responsibility as well. It is important for a facility to understand that this remains their process and their responsibility. Ask tough questions of your contractors to ensure that you understand the condition of your system.
Facility and Contractor Incident Release Response: On the day of the release at 03:53 the machine room NH3 alarm registered 300ppm. Responding facility personnel observed the brine expansion tank shaking and spilling brine. At 04:30, the facility personnel shutdown the system and closed the chiller suction valve, observing that the shaking in the brine tank stopped. This should have indicated to the facility personnel that the separation between the brine and NH3 sides was completely compromised and that the brine loop was now full of ammonia. At 05:18 the facility personnel called the contractor to come in and re-configure the system to operate without the brine chiller.
At some point during the work, the personnel isolated the brine chiller, trapping the ammonia-laden brine in the chiller with no outlet available for it. As this ammonia-laden brine warmed up, the pressure inside the brine chiller rose and, at an estimated pressure of 30-150psig, a coupling on the brine-side of the brine chiller failed releasing the contents into the machine room and onto the personnel in the room. The estimated total NH3 release was 22 pounds (9lbs immediately vaporizing) resulting in an immediate concentration in the area of 20,000ppm which dissipated to about 5,000ppm over a period of 5 minutes.
The report uses electricity demand to conclude that the personnel did not attempt a pump-out of the brine chiller. Unlike a CSB report, the report does not go into the fatalities. We have no idea where the personnel were positioned in the room, or what – if any – PPE they were wearing at the time of the release. It can reasonably be surmised that they weren’t wearing any respiratory PPE at all.
Possible PSM citations: 1910.119(g)(1)(i) for not training personnel of the hazards associated with NH3 contaminated brine and the hazards of trapping it. 1910.119(h)(3)(ii) for the contractor not being trained in the hazards associated with NH3 contaminated brine and 1910.119(h)(2)(v) for the facility not ensuring this training occurred. 1910.119(n) for not providing “procedures to handle small releases.” 1910.119(f)(1)(i)(D) for not providing an emergency shutdown procedure. 1910.119(f)(1)(i)(E) for not providing an emergency operations procedure.
Opportunity #9: While we often train on the dangers associated with trapping NH3, the dangers of trapping NH3 contamination in a secondary loop is rarely discussed. Operator training in facilities that utilize secondary cooling loops must address contamination and its possible safety implications.
Opportunity #10: While it’s not possible to know for sure, it is extremely likely that all three of these fatalities could have been avoided if the personnel were wearing full-face APRs at the time of release. Note: They would have to have been wearing them, not have them “near-by.” APR’s aren’t magic.
The Question:
Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement?
This question comes up from a customer several times a year.
The Short answer:
The answer – if you are short on time – is: An equipment change rarely qualifies as a Replacement in Kind.
The LONG answer:
First, let’s look at the relevant text of the PSM MOC requirement:
1910.119(l)(1) – The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process. (The RMP text is essentially the same, so we’re just going to focus on the PSM text)
This text is about the scope of the MOC requirement; or to put it another way: What triggers the requirement?
This proposed condenser change is obviously a change to equipment that has the potential to affect a covered process so it could be covered. In theory, if the new condenser does not affect a covered process we could classify it as a Replacement in Kind. Unfortunately, we don’t actually know if the new condenser will affect the process until we investigate the change. Some questions we’ll need to ask include (but are not limited to):
1) Are there piping / valving changes?
2) Is the overpressure protection the same?
3) Does the new equipment require any changes to the inventory calculation, relief calculation, equipment schedule, etc?
4) Are there any changes to the electrical requirements and controls?
5) Does the new equipment require any changes to existing SOP(s) and MIP(s)?
6) Does the new equipment require any changes to the existing MI schedule?
7) Does the new equipment require any changes to the existing Operator Training?
8) Does the new equipment require any change to the existing Process Hazard Analysis to ensure it properly identifies, evaluates and controls the hazards of the new equipment?
9) Are there any other ways that this new equipment could affect safety and health?
That’s a lot of questions to ask and it’s really just the beginning of them. To even consider this new equipment a Replacement in Kind, we’d have to ask all these questions (and more) and answer them with “No, there are no changes required”.
You know a great way to ensure that you ask these types of questions and properly document your answers? THE MOC ELEMENT. It is literally a written program to Manage Changes.
While it’s not very likely that you will go through the entire MOC procedure and find there are no required changes to the PSM program, if you did so, then you could properly quantify the replacement as a Replacement in Kind and you would have your written questions and answers to defend that judgement.
Where does the confusion come from?
Why do so many people think that these types of equipment changes are not covered by the MOC requirement? Often it’s as simple as getting bad advice from consultants or refrigeration “schools.” I think part of the confusion on the issue stems from legacy industry guidance. For the vast majority of Ammonia PSM practitioners, the IIAR is our go-to guidance on design, construction, startup, decommissioning, maintenance, etc., so it’s natural to refer to them for PSM guidance.
Here’s a section from the IIAR’s 1994 Guide to the Implementation of Process Safety Management for Ammonia Refrigeration:
Here’s the same section from the IIAR’s 2012 updated Process Safety Management and Risk Management Program Guidelines:
Some quick thoughts on that guidance:
1) The term “Like for like” does not exist in the text of the PSM or RMP rule(s) and only leads to more confusion.
2) The first bullet of the 1994 guidance muddles the issue with assumptions. In the legal realm this is referred to as “Assuming facts not in evidence” meaning that the argument is relying on data that hasn’t been provided. We don’t know if the “piping, specifications, connections, instrumentation, and controls” are identical until we actually perform the MOC or something A LOT like it.
3) The second bullet of the 1994 guidance and the revised 2012 guidance are clearer, but they suffer from the same problem with assumptions.
Note: The IIAR is currently updating the Process Safety Management and Risk Management Program Guidelines and I expect the new version to significantly alter this guidance.
Why does this matter?
Misclassifying a covered change as a Replacement in Kind often allows the facility to circumvent the Management of Change procedure.
Let me offer a real-world example: During a client visit it was discovered that they were having a replacement condenser installed and that they were classifying it as a Replacement in Kind. They explained that they were doing this because they treated a previous condenser replacement as a Replacement in Kind due to advice from a class one of their employees had attended. We started asking some questions and in under an hour found the following:
1) The relief valves had been removed from both condensers and replaced with hand valves and pipe stubs. (Presumably to allow manual purging)
2) The new stubs did not have caps installed and were therefore open to the atmosphere.
3) The P&IDs no longer reflected the as-built condition of the facility for either of the condensers.
4) The SOPs still referred to the OLD models, not the current ones.
5) The SOPs still referenced the removed relief valves.
6) The PHA section covering condensers still listed relief valves as a safeguard and therefore did not properly identify, evaluate and control the hazards of the condensers.
ALL the above issues would have been avoided with a properly conducted Management of Change procedure.
Original Post: RCE-Chill
Make your opinion known BEFORE the changes go final!
IIAR 6 continues its development. This document will replace IIAR Bulletin 110 (among others) and will be very important. The current review only lists changes since Public Review #2.
| To: | IIAR Members |
| Re: | Third (3rd) Public Review of Standard BSR/IIAR 6-201x, Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems. |
| A third (3rd) public review of draft standard BSR/IIAR 6-201x, Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.BSR/IIAR 6-201x, specifies the minimum requirements for inspection, testing, and maintenance applicable to stationary closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of ammonia refrigeration system(s) and basic ammonia refrigeration practices and principles. This standard is intended for those who inspect, test, and maintain stationary closed-circuit ammonia refrigeration systems. This standard shall apply only to stationary closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It supplements existing general refrigeration standards issued by IIAR and other organizations such as ASHRAE, ASME, and ANSI. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes).
IIAR has designated the draft standard as BSR/IIAR 6-201x. Upon approval by the ANSI Board of Standards Review, the standard will receive a different name that reflects this approval date. We invite you to participate in the third (3rd) public review of BSR/IIAR 6-201x. IIAR will use the American National Standards Institute (ANSI) procedures to develop evidence of consensus among affected parties. ANSI’s role in the revision process is to establish and enforce standards of openness, balance, due process and harmonization with other American and International Standards. IIAR is the ANSI-accredited standards developer for BSR/IIAR 6-201x and is responsible for the technical content of the standard. This site includes links to the following attachments: The 45-day public review period will be from July 6th, 2018 through August 20th, 2018. Comments are due no later than 5:00 pm Eastern Standard Time (EST) on August 20th, 2018. Thank you for your interest in the public review of BSR/IIAR 6-201x, Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems. |
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Head on over to RCE-Chill to see our latest worksite posters.
Today, EPA’s Administrator, E. Scott Pruitt, signed a new proposed rule, further changing the Obama-era EPA’s proposed changes and the EPA is submitting that for publication in the Federal Register (FR).
Basically, it outlines two proposals for the Obama-era EPA’s proposed changes:
While there is a lot of information to digest, the basic arguments for the changes the Trump-era EPA is making are:
As always, stay tuned for further information. We’re still years away from a change at this rate!
