← American Chemistry Council
EPARulemakingEPA-HQ-OEM-2014-0328

Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Section 112(r)(7); Rule Modernization Under Executive Order 13650; Request for Information

RIN
—
Last modified
Jun 12, 2024
Comment window
closed 4290d ago
American Chemistry Council filings
3

Activity

American Chemistry Council filed 3 comments on this docket between Sep 30, 2014 and Nov 6, 2014. 64 other organizations filed here. The comment window closed 4290d ago.

What American Chemistry Council filed (3)

Nov 6, 2014· Updated comment submitted by Rachel A. Meidl, Director, Regulatory & Technical Affairs, American Chemistry Council (ACC)· EPA-HQ-OEM-2014-0328-0694

To the Docket: The American Chemistry Council (ACC) is pleased to respond to the request for information issued by the U.S. Environmental Protection Agency (EPA) on potential revisions to EPAs Risk Management Program regulations and related programs. The request for information, Docket ID No. EPA-HQ-OEM-2014-0328 (RFI) was published in the Federal Register on July 31, 2014. ACC is Americas oldest trade association of its kind, representing companies across the United States engaged in the business of chemistry. ACC supports EPAs commitment, expressed in the RFI, and the commitment of the President of the United States as expressed in Executive Order (EO) 13650, to prevent chemical accidents and to prevent or minimize the consequences of accidental chemical releases through the implementation of management program elements that integrate technologies, procedures and management practices. ACC members would be directly affected by EPAs promulgation of revisions to the existing RMP rule, whether those revisions expand the RMP rule to include additional regulated substances and hazards, update the RMP rule in parallel to the effort undertaken by OSHA to evaluate updates to OSHAs PSM rule, or change the RMP requirements in any of the various ways explored in the RFI. While ACC shares EPAs goals of preventing chemical accidents and preventing or minimizing the consequences of accidental chemical releases, ACC has a number of concerns about the proposed changes identified by EPA in the RFI, as outlined in our attached comments. We believe that the potential changes to the RMP rules considered in the RFI would in many cases represent a drastic departure from the current regulatory framework, in some instances with adverse impacts, and in other instances without corresponding benefits, to chemical accident prevention or workplace or employee safety. Ultimately, ACC believes that the most influential steps EPA could undertake to improve chemical safety is through increased awareness of existing management and regulatory programs, enhanced training, and enforcement for companies that have not shown themselves to be capable of implementing the rule. ACC shares a common goal with EPA, OSHA and other stakeholders to create and maintain safe workplaces for our nations employees, the environment, and for our surrounding communities. Thank you for the opportunity to submit these comments on the RFI. Should you have questions, please contact the undersigned by phone at (202) 249-6426 or by email at Rachel_Meidl@americanchemistry.com. Respectfully submitted, Rachel A. Meidl Director, Regulatory & Technical Affairs American Chemistry Council 700 Second Street, NE Washington, DC 20002

View on regulations.gov →
Nov 3, 2014· Comment submitted by Rachel A. Meidl, Director, Regulatory & Technical Affairs, American Chemistry Council (ACC)· EPA-HQ-OEM-2014-0328-0616

To the Docket: The American Chemistry Council (ACC) is pleased to respond to the request for information issued by the U.S. Environmental Protection Agency (EPA) on potential revisions to EPAs Risk Management Program regulations and related programs. The request for information, Docket ID No. EPA-HQ-OEM-2014-0328 (RFI) was published in the Federal Register on July 31, 2014. ACC is Americas oldest trade association of its kind, representing companies across the United States engaged in the business of chemistry. ACC supports EPAs commitment, expressed in the RFI, and the commitment of the President of the United States as expressed in Executive Order (EO) 13650, to prevent chemical accidents and to prevent or minimize the consequences of accidental chemical releases through the implementation of management program elements that integrate technologies, procedures and management practices. ACC members would be directly affected by EPAs promulgation of revisions to the existing RMP rule, whether those revisions expand the RMP rule to include additional regulated substances and hazards, update the RMP rule in parallel to the effort undertaken by OSHA to evaluate updates to OSHAs PSM rule, or change the RMP requirements in any of the various ways explored in the RFI. While ACC shares EPAs goals of preventing chemical accidents and preventing or minimizing the consequences of accidental chemical releases, ACC has a number of concerns about the proposed changes identified by EPA in the RFI, as outlined in our attached comments. We believe that the potential changes to the RMP rules considered in the RFI would in many cases represent a drastic departure from the current regulatory framework, in some instances with adverse impacts, and in other instances without corresponding benefits, to chemical accident prevention or workplace or employee safety. Ultimately, ACC believes that the most influential steps EPA could undertake to improve chemical safety is through increased awareness of existing management and regulatory programs, enhanced training, and enforcement for companies that have not shown themselves to be capable of implementing the rule. ACC shares a common goal with EPA, OSHA and other stakeholders to create and maintain safe workplaces for our nations employees, the environment, and for our surrounding communities. Thank you for the opportunity to submit these comments on the RFI. Should you have questions, please contact the undersigned by phone at (202) 249-6426 or by email at Rachel_Meidl@americanchemistry.com. Respectfully submitted, Rachel A. Meidl Director, Regulatory & Technical Affairs American Chemistry Council 700 Second Street, NE Washington, DC 20002

View on regulations.gov →
Sep 30, 2014· Comment submitted by Rachel A. Meidl, Director, Regulatory & Technical Affairs, American Chemistry Council (ACC)· EPA-HQ-OEM-2014-0328-0295

Filed on regulations.gov — full text not in the inline record.

View on regulations.gov →

Abstract

In response to Executive Order 13650, EPA requests comment on potential revisions to its Risk Management Program regulations and related programs. In this Request for Information (RFI), the Agency asks for information and data on specific regulatory elements and process safety management approaches, and the public and environmental health and safety risks they address. EPA will use the information received in response to this RFI to determine what action, if any, it may take.

View on regulations.gov →

Co-filers (64)

See everyone who commented →