EPA issued a new proposed RMP rule on March 14, 2016. Proposed changes to the RMP regulation will add significantly to requirements for audits, incident investigations, local coordination, emergency response planning and exercises, and information sharing. The proposed rule is essentially divided into two parts: accident prevention and accident mitigation. Under these new requirements, industrial hygienists should expect to become more involved in many elements of process safety. On the prevention side, industrial hygienists’ roles will likely include performing compliance audits; providing worker health and safety insights for process hazard analysis (PHA); reviewing operating procedures; and conducting incident investigations and root-cause analyses. As part of the mitigation piece, industrial hygienists may have more involvement with emergency planning and response and developing documents for information sharing. For both prevention and mitigation, IHs will likely play a larger role in training and analysis of safer alternatives. Of these elements, industrial hygienists are currently least involved with safer alternatives analysis, an area mostly handled by engineers and chemists; however, there is room for increased IH involvement. A significant aspect of the proposed RMP rule is the requirement for third-party auditing following any RMP reportable accident or release from a covered process, or if EPA deems it necessary. The agency’s 1996 RMP final rule defines a covered process as one containing a threshold quantity of a regulated chemical. A reportable accident is any accidental release from a covered process that results in death, injury, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. To add credibility to third-party auditors, EPA is proposing that professional engineers be required to conduct or participate in audits due to ethical codes associated with the PE license. However, the agency is considering the inclusion of additional certifications such as CIH, CSP, and CHMM as alternatives to the PE requirement. Inclusion of these certifications as approved auditors for RMP would add significant value to the industrial hygiene profession and expand IH involvement in process safety. Even without the certification requirement for RMP auditors, industrial hygienists can still serve as a valuable resource in these audits by evaluating compliance with requirements for incident investigations, training, updating health and safety information, and maintaining proper PSI. EPA is proposing the addition of a requirement to conduct a safer alternatives analysis during the process hazard analysis (PHA). A safer alternatives analysis identifies strategies for making processes, procedures, and equipment safer through minimization, substitution, moderation, and simplification. Industrial hygienists may be particularly qualified to participate in PHAs and safer alternatives analysis. Traditionally, PHAs focus on engineering and design controls of chemical processes, but many industrial hygiene-related concerns are also evaluated. In part, a PHA evaluates engineering and administrative controls, working conditions that may influence employees’ ability to properly complete tasks, and the safety and health of employees. A PHA also involves assessing the potential effects of catastrophic events on emergency responders, the public, and the environment. EPA’s proposed rule will require root-cause analysis following any RMP reportable accident or near miss. Although the agency has not yet defined a specific methodology for a root-cause analysis, industrial hygienists may again be particularly qualified to lead or participate in root-cause analyses depending on the incident. While a certain level of emergency response planning and coordination is required under current regulations, EPA is proposing to improve public awareness; the quality and quantity of training; and coordination and information sharing with local emergency response authorities. This part of the proposal echoes CSB’s report on its investigation into the West Fertilizer fire and explosion, which identified improved emergency response planning, information sharing, and communication as factors that likely would have reduced the numbers of injuries and fatalities. Because proper emergency response during a chemical release requires specific knowledge of chemical and physical hazards, industrial hygienists’ involvement in emergency response planning and coordination can prove essential. Industrial hygienists should help develop publicly shared documents identifying site hazards and participate in emergency planning and training exercises with local responders. Larger and more proactive LEPCs and other government agencies may seek industrial hygienists as consultants for participation, training, emergency planning, and responses. For industrial hygienists who work or consult for regulated companies, sharing information on hazardous regulated substances with local emergency responders will provide useful site-specific details that could be critical in the event of an emergency. Clarification of site hazards and site-specific emergency response exercises will ultimately lead to safer facilities. OSHA’s new PSM standard is still relatively early in the regulatory process. The agency’s 2013 request for information asked for data on some of the same PSM additions or modifications that are proposed for RMP, including root-cause analysis, safer technology analysis, third-party audits, and emergency response coordination and planning. OSHA has also requested information for potential inclusion of explosive and reactive chemicals on the list of regulated chemicals, and expansion of scope to the drilling and servicing of oil and gas wells. As this issue went to press, OSHA intended to hold small business advocacy review teleconferences in late June. The teleconferences were scheduled to address a number of topics, including updating the list of highly hazardous chemicals in the PSM standard; requiring additional management-system elements; and expanding PSM coverage and requirements for reactivity hazards. The full list of topics can be found on the OSHA . Following the small business review, the review panel will compile comments submitted by pre-selected small entity representatives and complete a report providing feedback on the PSM revisions. The report will be placed in the federal docket on Aug. 1. If industrial hygienists are being left out of process safety, it is a disservice to the safety of workers and the public and a detriment to the IH profession. As the modernization of process safety progresses, industrial hygienists will play a major role in its support and implementation, and should expect to be deeply entrenched in recognition, evaluation, control, and prevention of catastrophic chemical accidents. Depending on where the final regulations land, industrial hygienists may also be incorporated into supporting roles such as auditing. Initially, IHs may need to proactively insert themselves into the many aspects of process safety management at their workplaces.