AMWA is in the process of finalizing its comments in response to EPA’s Request for Information (RFI) published in the July 31 Federal Register. The RFI is 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.
The RFI requests stakeholder comment on numerous aspects of the RMP, but AMWA’s comments focus on two sections that directly relate to drinking water facilities. These sections seek feedback on whether EPA should require covered facilities to further evaluate or implement “inherently safer technologies” (IST), and whether water systems currently covered by the “Program 2” level of RMP oversight should be automatically reassigned to “Program 3.”
Consistent with our historical position on the issue, AMWA does not think EPA should impose any IST review or implementation requirements on water systems subject to the RMP. Additionally, EPA should not automatically reclassify “Program 2” drinking water facilities into “Program 3.”