ACC Balks At Proposed Changes To EPA Risk Management Program Rule

Nov. 2, 2022
The ACC believes the EPA’s proposed changes impose questionable regulatory mandates on an already successful approach for enhancing safety.

In written comments submitted to the Environmental Protection Agency (EPA) regarding its proposed changes to the Risk Management Program (RMP) rule, the American Chemistry Council (ACC) expresses concern that the agency’s proposal discards an already successful approach for enhancing safety to impose questionable regulatory mandates. Dr. Kimberly Wise White, vice president of regulatory and scientific affairs explains what the organization considers the main problem with EPA’s proposal:

“We are very concerned EPA has abandoned a collaborative and data-driven process and is proposing unnecessary changes that will not improve safety,” says Wise White in a press release from ACC. “The agency has not provided sufficient evidence to justify its proposed mandates, nor has it provided adequate time to review a wide range of complex issues.”

The current RMP rule requires facilities to assess the potential impacts of chemical incidents and to maintain comprehensive accident prevention and emergency response programs. These requirements include sharing information with local officials and emergency responders as well as addressing a range of potential safety risks, including natural hazards, according. ACC points out that this approach has helped drive down chemical related incidents by nearly 75% according to EPA data. Further analysis reportedly shows that nearly three-quarters of regulated facilities have no accident history. These figures suggest that targeted enforcement of existing regulations could substantially reduce the number of incidents instead of imposing sweeping new requirements, according to ACC.

While the ACC says there are certain aspects of the proposed rule that it supports – notably the approach to root cause analysis - there are several significant areas of concern that stand out.

ACC is concerned that the proposed rule removes important safeguards put in place after the 9/11 attacks to prevent the misuse of security sensitive information. ACC also believes the agency’s proposal to impose a Safer Technology and Alternative Assessment (STAA) requirement is unwarranted and unduly burdensome. The organization says that the EPA has not provided adequate evidence to support expanding requirements for assessing natural hazards.

Read the entire press release at

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