Accidental Release Prevention Requirements: Risk management Programs Requirements Under Clean Air Act Section 112(r)(7); Amendments to the Submission Schedule and Data Requirements

API is the primary trade association representing the oil and natural gas industry in the United States. Its membership includes more than 400 corporations involved in all aspects of the oil and gas industry including exploration, production, marine transportation, pipelines, refining, marketing, and businesses that serve and supply the oil and gas industry. API and its members are committed to protecting the health and safety of its workers and the general public. Many API member facilities have filed a Risk Management Plan (RMP), and therefore are impacted by any proposed change to these regulations. Topics coverd in the attached comments include: 1.) Proposed Trigger For Immediate RMP Resubmission and Recertification—68 FR 45127 (Section II. A. 1.) 2.) Emergency Contact Information—68 FR 45127 (Section II. A. 2.) 3.) Emergency Contact Email Address—68 FR 45128 (Section II. C. 1) 4.) Contractor Information—68 FR 45129 (Section II.C. 3.) 5.) Submitting OSHA Occupational Injury and Illness Data—68 FR 45129 (Section III) Thank you again for the opportunity to comment. If you have any difficulty reading the attachment, please contact Ted Steichen at 202-682-8568 or steichent@api.org.