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EPARulemakingEPA-HQ-OEM-2015-0725

Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act

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Last modified
Oct 29, 2025
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closed 274d ago
American Chemistry Council filings
6

Activity

American Chemistry Council filed 6 comments on this docket between Mar 16, 2016 and Aug 28, 2018. 139 other organizations filed here. The comment window closed 274d ago.

What American Chemistry Council filed (6)

Aug 28, 2018· Comment submitted by William J. Erny, et al., American Chemistry Council (ACC)· EPA-HQ-OEM-2015-0725-1628

Attached are comments submitted by the American Chemistry Council.

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Jun 27, 2018· Written Testimony of Bill Erny, American Chemistry Council Submitted to the Office of Emergency Management, USEPA at the June 14, 2018 Public Hearing on the RMP Proposed Rule Held at USEPA, Washington, DC· EPA-HQ-OEM-2015-0725-0964

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

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May 25, 2017· Comment submitted by Leslie A. Hulse, Assistant General Counsel, American Chemistry Council (ACC)· EPA-HQ-OEM-2015-0725-0833

Comments of the American Chemistry Council

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May 17, 2016· Comment submitted by William J. Erny, American Chemistry Council (ACC)· EPA-HQ-OEM-2015-0725-0537

Please accept the attached comments on behalf of the American Chemistry Council.

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Apr 15, 2016· Comment submitted by William J. Erny, American Chemistry Council (ACC)· EPA-HQ-OEM-2015-0725-0364

The American Chemistry Council (ACC) is pleased to submit these comments on EPA's proposed Risk Management Program (RMP) rule, EPA Information Collection Request (ICR) number 2537.01.

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Mar 16, 2016· Comment submitted by William J. Erny, Senior Director, American Chemistry Council (ACC)· EPA-HQ-OEM-2015-0725-0288

The American Chemistry Council respectfully requests that EPA extend the comment deadline for the proposed rule on EPA Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Section 112(r)(7) for an additional 30 days from May 13 to June 13, 2016. We also request that EPA extend the comment period for the Information Collection Request (ICR 2537) from April 13 to May 13, 2016. Given the complexity and magnitude of this proposed rule and the impact it will have on our members and all members of the RMP regulated community, we do not believe 60 days and 30 days respectively is sufficient to address all aspects of this proposal effectively. Should you have questions or would like to discuss this matter, please contact me by phone at (202) 249 6412 or by email at bill_erny@americanchemsitry.com. See attached file(s)

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Abstract

EPA is proposing several changes to the final Risk Management Program Amendments rule (Amendments rule) issued on January 13, 2017, whose effective date has been delayed until February 19, 2019. EPA is proposing to rescind amendments relating to safer technology and alternatives analyses, third-party audits, incident investigations, information availability, and several other minor regulatory changes and to modify amendments relating to local emergency coordination and emergency exercises, along with their compliance dates.

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Co-filers (139)

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