Section 6 of Executive Order 13650: Improving Chemical Facility Safety and Security

NOTE: The appended comments supersede ACC's earlier filing to Docket No. OSHA-2013-0026. Please disregard ACC's attachment submitted with Comment Tracking Number 1jy-8b9x-071i. To the Docket: The American Chemistry Council (ACC) is pleased to respond to Executive Order 13650, Section 6(a) – Solicitation of Public Input on Options for Policy, Regulation, and Standards Modernization, Docket No. OSHA-2013-0026. ACC encourages the Executive Order Working Group to consider the fundamental concerns outlined in the subsequent comments as the agencies proceed with the next step in the Executive Order 13650 process. As an alternative to rulemaking, ACC recommends that agencies, including OSHA, EPA and others, evaluate the use of non-regulatory means to help the Working Group achieve its goal of creating a safer workplace for our nation's employees and surrounding communities. We hope that the EO Working Group will find our contributions helpful. Should you have questions, please contact me by phone at (202) 249-6426 or by e-mail at rachel_meidl@americanchemistry.com. Respectfully submitted, Rachel A. Meidl Director, Regulatory & Technical Affairs American Chemistry Council 700 Second Street, NE Washington, DC 20002 Rachel_Meidl@americanchemistry.com

To the Docket: The American Chemistry Council (ACC) is pleased to respond to Executive Order 13650, Section 6(a) – Solicitation of Public Input on Options for Policy, Regulation, and Standards Modernization, Docket No. OSHA-2013-0026. ACC encourages the Executive Order (EO) Working Group to consider the fundamental concerns outlined in the appended comments as the agencies proceed with the next step in the EO process. As an alternative to rulemaking, ACC recommends that agencies including OSHA, EPA, and others evaluate the use of non-regulatory means to help the EO Working Group achieve its goal of creating a safer workplace for our nation's employees and surrounding communities. ACC hopes that the EO Working Group will find our contribution helpful. Should you have questions about our input, please contact me by phone at (202) 249-6426 or by e-mail at rachel_meidl@americanchemistry.com. Respectfully submitted, Rachel A. Meidl Director, Regulatory & Technical Affairs American Chemistry Council 700 Second Street, NE Washington, DC 20002