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NACD Feedback on Proposed EPA Adjustments to Chance Control Plan Rule

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The Nationwide Affiliation of Chemical Vendors (NACD) submitted feedback to the U.S. Environmental Coverage Company (EPA) urging the company to rethink its proposed adjustments to the Chance Control Plan (RMP) rule.

Within the feedback, NACD Vice President of Regulatory Affairs Jennifer Gibson highlighted the effectiveness of the present RMP rule at fighting chemical injuries and instructed the company to rethink its blanket necessities on all companies, together with the ones already in compliance.

“As a substitute of requiring new rules for all amenities coated via RMP, the EPA will have to center of attention on amenities which can be noncompliant and/or experiencing nearly all of injuries,” writes Gibson. “NACD urges the EPA to center of attention its efforts on those amenities as a substitute of widely making use of new rules to all RMP amenities, the majority of which might be in compliance and feature effectively avoided unintended releases.”

Gibson additionally raised issues over the useless and burdensome rules that may position further pressure on chemical vendors, specifically small companies.

“Moreover, when assessing the prices of the proposal, it seems that that making sure compliance might be expensive to companies,” states Gibson. “Making an allowance for those prices, along with the exertions hours and administrative prices hooked up to different provisions of this proposal, NACD individuals estimate that the associated fee in step with facility may just simply exceed $100,000 in step with 12 months.”

Gibson concludes, “Developing a last rule that provides further necessities would possibly lead to amenities defunding vital and confirmed mitigation sources to make sure they may be able to finance those new provisions. NACD urges the EPA to withdraw the proposed rule and make allowance the present RMP rules to proceed to function effectively.”

To learn NACD’s complete feedback submitted to the EPA, click on right here.

On August 22, 2022, NACD President and CEO Eric R. Byer launched a commentary voicing fear with the EPA’s proposed adjustments to the RMP rule.

On July 26, 2021, NACD spoke back to EPA’s request for touch upon revisions to the RMP program to underscore the affects of this attainable alternate. The ones feedback are to be had right here.  

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