1,3-Butadiene

Re: ACC Butadiene Consortium Comments on OSHA's Proposal to Revise the 1,3-Butadiene Standard, Docket No. OSHA-2025-0020 Dear Mr. Levinson: The American Chemistry Council (ACC) Butadiene Consortium (Consortium) appreciates the opportunity to submit comments to OSHA's reopened rulemaking record for the proposed revisions to OSHA's 1,3-Butadiene-Specific Occupational Standard, 29 CFR § 1910.1051. The Consortium generally supports OSHA's proposed revisions to the substance-specific standard, as these updates recognize advances in respiratory protection and other personal protective technologies and provide greater flexibility for employers and employees while continuing to maintain worker protection. However, the Consortium is concerned that certain changes to these standards could conflict with risk management requirements being considered by the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA). Accordingly, we urge OSHA and EPA to establish robust coordination and consultation procedures in situations where regulatory requirements may overlap or be duplicative. In particular, as EPA develops new or revises existing TSCA risk management rules, it should, to the extent practicable, rely on existing OSHA regulations and harmonize any new TSCA requirements with OSHA's established regulatory framework. The Consortium appreciates OSHA's effort to modernize the 1,3-Butadiene standard and supports finalizing revisions that improve clarity, allow use of modern protective technology, and reduce unnecessary burden while maintaining worker protection. As OSHA evaluates comments submitted during the reopened rulemaking record, the Consortium urges OSHA to consider the broader federal worker-safety landscape in which this rule will operate. 1,3-Butadiene occupational exposure is already addressed through OSHA's chemical-specific standard. Any future federal action affecting worker exposure to 1,3-Butadiene should be coordinated to avoid duplicative or conflicting occupational requirements between OSHA and EPA. Workers and employers are best served by one coherent, federal workplace safety framework that is clear, feasible, enforceable, and grounded in OSHA's occupational safety and health expertise. The Consortium appreciates the opportunity to comment on OSHA's proposed changes to the substance-specific standard. Should you have additional questions, please feel free to contact me at neeraja_erraguntla@ americanchemistry.com Kind regards, Neeraja Erraguntla Director, Chemical Products and Technology

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