Sunday, September 14, 2014

Public Comments on EPA RMP RFI – 09-14-14

This is the first in a series of blog posts about the public comments provided to the EPA about their request for information (RFI) about potential changes to their Risk Management Program. This RFI was mandated by the President’s Executive Order on Increasing Chemical Safety and Security (EO 13650). To date there have been 340 comments submitted with only 16 of those being posted to the comment docket.

Most of these early comments have come from members of the public. For the most part these are comments from people that feel that they are affected by potential chemical releases of various sorts in their communities. They range from strong proponents of requiring inherently safer technology (IST) implementation to banning of mercury containing light bulbs to people who are fed up with Federal regulations in general. Surprisingly there is no evidence of any organized letter writing campaign to date.

There are a disturbing number of ‘anonymous’ submissions. None of them seem to target specific companies or espouse any real extremist views so it does not seem that they are anonymous because of fear of retaliation. There is one anonymous comment that is quite detailed and deserves much more consideration than most such comments. This is may be an individual that works in the chemical industry and fears that his pro-regulatory comments might not be appreciated by his employer.

There is an interesting, if very brief, submission by Prof. Nicholas Ashford of MIT. He had earlier submitted two documents related to the topic and was apparently concerned that they had not been received because they did not show up on the docket. The EPA acknowledges the receipt of these two documents but notes that due to copyright restrictions they are only available at the EPA Reading Room in Washington. This may be an explanation of why some of the other 340 comments do not show up in the docket.

There are two comments posted by industry consultants. The first (in order of submission) was from Terry Hardy and it points out the failure of the current (and proposed) RMP program to specifically address the safety issues related to the use of industrial control systems. The second was from Robin Pitblado that provided a brief discussion supporting the use of the safety case regime in regulating chemical safety.

The most interesting (from my point of view working in the chemical industry) was a submission from Capt. Pete Brummel an Eastside, WA based fire fighter concerning drills conducted with the Tolt Water Treatment Facility. It is a very simple testament to cooperation between facilities and their supporting first responders. There isn’t much in the way of suggestions for the RMP regulations, but it is something that should be taken into account by the writers of any new regulations.

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