SOURCE: National Association of Chemical Distributors

National Association of Chemical Distributors

October 29, 2014 16:28 ET

NACD Files Comments on EPA Risk Management Program

ARLINGTON, VA--(Marketwired - October 29, 2014) - Today, the National Association of Chemical Distributors (NACD) submitted comments to the Environmental Protection Agency (EPA) on its request for information (RFI) on potential changes to the agency's Risk Management Program (RMP) overseeing chemical facilities. EPA requested information and data on specific regulatory elements and process safety management approaches, the public and environmental health and safety risks they address, and the costs and burdens they may entail.

In its comprehensive comments, NACD expressed concerns about several elements in the RFI including proposals to expand RMP coverage and requirements for reactivity hazards, to require third-party compliance audits, to require facilities to conduct safer technology and alternatives analyses, and to amend the worst case release scenario quantity requirements for processes involving multiple small vessels stored together. The comments also urged EPA to work with other government agencies and state/local organizations to increase compliance with emergency response program requirements in coordination with local responders, and streamlining RMP mandates.

Stated NACD Vice President of Regulatory Affairs Jennifer Gibson, "In all discussions of process safety, the examples of facility safety concerns articulated by those speaking to this issue have actually been examples of facilities not complying with existing regulations-not a lack or gap in the existing requirements. Developing additional regulations fails to address the problem of outlier operations." 

Continued Gibson, "In order to prevent chemical accidents, EPA needs to focus its efforts on better coordination with other federal and state agencies, more RMP compliance assistance and training, effective enforcement, and targeting outliers rather than adding unnecessary complexities to the regulation."

To view NACD's complete comments, click here.

NACD and its nearly 440 member companies are vital to the chemical supply chain providing products to over 750,000 end users. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and a third-party verified management practice. For more information, visit

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