On July 31, EPA published a Request for Information (RFI) in the Federal Register seeking information and data to inform potential regulatory changes to its Risk Management Program (RMP). The RFI was issued in response to Executive Order 13650: Improving Chemical Facility Safety and Security, which requires EPA to review chemical hazards covered under existing RMPs and evaluate potential improvements to applicable regulations.
Among the topics on which EPA will seek stakeholder input is how the agency should promote or require the use of “inherently safer technologies” (IST). The RFI explains planned agency activities to promote IST, including issuing a joint alert with the Occupational Safety and Health Administration “illustrating the concepts, principles and examples of safer technology and alternatives, and publishing a voluntary guidance document to explain how operators may reduce risks by employing safer technology and alternatives.” Based on subsequent stakeholder feedback to these publications and the RFI, EPA said it might consider amending RMP regulations to require analysis and documentation of IST by facility operators or implementation of IST alternatives where feasible.
To inform these decisions, the RFI seeks answers to questions such as how facilities should determine whether a particular safer alternative exists and is feasible, whether covered facilities’ own IST analyses should be submitted to EPA for review, what are potential barriers to and economic impacts of IST implementation, and what types of facilities should be subject to any future IST regulations.
Stakeholders have until October 29, 2014 to provide comment in response to the RFI. AMWA staff will be reaching out to members in the coming weeks to seek feedback for comment submission.
Additional information on this process, including links to the Federal Register notice and Executive Order 13650, can be found on EPA’s Executive Order on Improving Chemical Facility Safety and Security website.