The purpose of this memorandum is to issue and make immediately effective, the attached document, "Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)." This document updates and supersedes the "Guidance for Auditing Risk Management Plans/Programs under Clean Air Act Section 112(r)" of August 1999. The document includes updated EPA policy on involvement of facility employees and employee representatives in EPA and delegated agency on-site compliance inspections as provided for in Clean Air Act (CM) section 112(r)(6)(L).
While EPA staff may already engage employees and employee representatives during CAA Section 112(r) inspections, the updated guidance provides formal EPA policy in this area. Additionally, the guidance reflects the Agency's focus on inspections as a means of facility oversight, and provides additional information on CAA Section 112(r) inspection procedures.