EPA Increases Scrutiny of Chemical Facilities: How Safety Leaders Can Prepare

Evolving EPA enforcement strategies under the Clean Air Act's Risk Management Program require chemical facility managers to bridge worker process safety with community emergency response documentation.

• By Krista McIntyre
• July 13, 2026

Facilities that handle hazardous chemicals are facing increased attention from federal regulators as the U.S. Environmental Protection Agency (EPA) expands inspections under the Clean Air Act's Risk Management Program (RMP) and the Emergency Planning and Community Right-to-Know Act (EPCRA).

Across EPA regions, facilities covered by the RMP are reporting advance notice inspections accompanied by short deadline extensive requests for records and documentation before inspectors even arrive on site. The trend signals active enforcement and underscores the importance of maintaining inspection-ready safety and compliance programs.

EPA’s RMP inspections inherently touch Occupational Safety & Health Act (OSHA) Process Safety Management (PSM) compliance activities because many program elements are shared. In some organizations, compliance responsibilities for both RMP and PSM reside in the same individual or team. While OSHA PSM focuses on protection of workers and RMP focus is on community impacts, both impose obligations to prevent and minimize risk of accidental releases.

Coordination among EHS managers responsible for both is essential to compliance success. EPA’s increased inspection activity comes at a time of heightened public attention on chemical process safety following several high-profile industrial incidents. In May 2026, a chemical storage tank incident in Garden Grove, California, prompted the evacuation of tens of thousands of residents as emergency responders worked to prevent a catastrophic release.

Around the same time, a chemical tank rupture at a paper mill in Longview, Washington triggered investigations by federal and state agencies and renewed discussions about process safety management, mechanical integrity and emergency preparedness.

While EPA does not directly link the current inspection activity to these incidents, major industrial accidents often lead regulators to revisit accident prevention programs and compliance practices across facilities that handle hazardous substances. For safety professionals, the message is clear: regulators are refreshing emphasis on compliance demonstrations to show that safety systems are functioning effectively and that employees are able to prevent and respond to chemical incidents.

According to EPA, the Risk Management Program is designed to prevent accidental releases that could harm workers, emergency responders, nearby communities and the environment.

Covered facilities are required to identify hazards, implement accident prevention measures and coordinate emergency response activities with local authorities. Organizations that can demonstrate strong safety culture, employee engagement, effective training programs and well-maintained equipment and records are generally better positioned during inspections.

What EPA Is Inspecting

Recent inspection activity suggests EPA is taking a comprehensive approach when evaluating covered facilities.

Inspections may last several days and often involve multiple EPA and contracted inspectors reviewing records, touring facilities and interviewing personnel. EPA guidance prompts inspectors to evaluate both program documentation and evidence that programs are being implemented effectively.

Areas commonly reviewed include:

• Risk Management Plan submissions
• Process Safety Information (PSI)
• Process Hazard Analyses (PHAs)
• Operating procedures
• Employee training programs
• Mechanical Integrity programs
• Management of Change (MOC) procedures
• Incident investigations
• Contractor safety management
• Emergency response planning
• Tier II chemical inventory reporting

Inspectors may photograph regulated process areas and review chemical inventories, equipment condition, and emergency preparedness measures. For many organizations, the challenge is not the existence of these programs but the ability to quickly produce documentation to demonstrate compliance.

Building an Inspection-Ready Organization

One of the most effective ways to prepare for increased regulatory attention is to establish an inspection readiness program that incorporates readiness into routine EHS management. An inspection readiness team typically includes representatives from:

• EHS
• Operations
• Maintenance
• Process safety
• Emergency response
• Training and human resources
• Facility leadership

Designating a primary inspection coordinator can help ensure consistent communication, organized documentation and efficient responses to inspector requests.

Facilities should also establish procedures for employee communications, document control and inspector escorts before an inspection occurs.

Regular readiness reviews can help identify gaps before regulators do and provide opportunities for continuous improvement.

Review Training Records Before Inspectors Do

Training is a frequently scrutinized aspect of process safety programs. Inspectors often seek evidence that employees have received initial and refresher training and that organizations document employees’ understanding of operating procedures and emergency response responsibilities.

Questions safety leaders should ask include:

• Are training records current and complete?
• Can records be retrieved quickly?
• Is competency verification documented?
• Are contractor training records readily available?
• Are refresher training requirements being met consistently?

Even organizations with strong training programs can encounter compliance challenges if supporting documentation is incomplete, inconsistent or difficult to access. Routine reviews of training records can help reduce last-minute preparation efforts and improve confidence during inspections.

Evaluate Process Safety Documentation

Documentation remains a critical component of demonstrating compliance and operational discipline. Facilities should periodically review:

• Process Safety Information: Confirm that process descriptions, equipment information, diagrams and safety system documentation accurately reflect current details.
• Process Hazard Analyses: Verify that analyses are current and that recommendations have been evaluated, tracked and addressed appropriately.
• Operating Procedures: Ensure procedures reflect actual operating conditions and are reviewed and certified.
• Mechanical Integrity : Track audit findings with risk ranking, assignments for task completion, and deadlines.
• Management of Change: Review whether modifications to equipment, processes or procedures have been properly documented, communicated and implemented.

Maintaining complete records not only supports compliance but also strengthens operational consistency and risk reduction efforts.

Emergency Preparedness Deserves Special Attention

Emergency preparedness is a major area of EPA focus. Inspectors may review:

• Emergency response plans
• Evacuation procedures
• Emergency notification systems
• Coordination with local emergency responders and documentation
• Tabletop exercise records
• Field exercise documentation
• Respiratory protection programs

Safety leaders should ensure that coordination with local emergency planning committees (LEPCs), fire departments and other response organizations is documented and current. Many organizations routinely communicate with local responders but fail to maintain records demonstrating that coordination occurred.

Facilities should also periodically evaluate whether emergency plans reflect current operations, staffing levels and potential release scenarios.

Conduct a Pre-Inspection Walkthrough

The facility tour often shapes an inspector's initial impression of a site's safety culture.

Before an inspection, conduct an internal walkthrough focused on identifying visible issues such as:

• Missing equipment labels
• Inaccessible emergency equipment
• Damaged safety signage
• Poor housekeeping
• Missing inspection tags
• Ventilation concerns
• Access-control deficiencies

These visual cues can influence how inspectors view overall program effectiveness. A well-maintained facility demonstrates operational discipline and attention to detail.

Organize Documentation Before It Is Requested

One of the most common challenges is producing records under time pressure. Facilities can improve readiness by organizing documents according to major program elements, including:

• Process Safety Information
• Process Hazard Analyses
• Training
• Mechanical Integrity
• Required Audits
• Management of Change
• Incident Investigations
• Emergency Response
• Community Coordination
• Tier II Reporting

Maintaining electronic files in a centralized location can significantly reduce administrative burdens during inspections. 

Requesting reasonable time to prepare, review, and organize records before release to the inspector is appropriate and usually necessary.

Use EPA Resources as a Self-Assessment Tool

EPA publishes several resources that can help organizations evaluate their readiness before an inspection occurs.

Among the most useful is the agency's Program 3 Process Checklist, which outlines the types of records and program elements inspectors commonly review.

Used appropriately, the checklist can help facilities:

• Identify documentation gaps
• Verify program implementation
• Improve record organization
• Prepare personnel for inspections
• Strengthen internal audits

The checklist also provides valuable insight into how inspectors evaluate compliance across major process safety elements and can serve as a practical roadmap for readiness reviews.

Create a Culture of Compliance

The most successful organizations do not prepare for inspections only after receiving notice from regulators. Instead, they build inspection readiness into everyday operations through strong documentation practices, employee engagement, routine self-assessments and continuous improvement efforts.

Facilities that maintain current records, conduct regular training, verify emergency response capabilities and routinely evaluate process safety programs are often better positioned when inspectors arrive. More importantly, these same practices help reduce the likelihood of incidents that can endanger workers, surrounding communities and the environment.

As EPA continues emphasizing chemical accident prevention and emergency preparedness, safety leaders have an opportunity to strengthen both compliance performance and operational resilience.

By treating inspection readiness as an extension of effective risk management, organizations can improve safety outcomes while demonstrating a strong commitment to worker protection, community safety and regulatory compliance.