Oct 1, 2014

ACA Asks EPA for Comment Deadline Extension on RFI for Risk Management Programs

Javaneh Nekoomaram- On Sept. 23, ACA asked the U.S. Environmental Protection Agency (EPA) to extend for 90 days the comment deadline for its http://www.gpo.gov/fdsys/pkg/FR-2014-07-31/pdf/2014-18037.pdf
Request for Information (RFI) on Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). This would allow comments to be submitted by Jan. 27, 2015 rather than the current deadline of Oct. 29, 2014.

In its request, ACA stated that the initial 90-day comment period is inadequate and impractical to effectively collect and analyze information on such an expansive and complex RFI. In the RFI, EPA asks for detailed information on costs and economic impacts, including quantitative benefits, costs, compliance costs, and offsets to costs, as well as specific information about any technical feasibility issues or implementation challenges associated with the various proposals. In order to appropriately respond to the topics discussed in the RFI, stakeholders need time to perform extensive technical evaluation and quantitative analyses. The breadth and complexity of the questions are wide-ranging, spanning 19 topics with more than 100 options and over 380 inquiries, some consisting of multiple part questions.

EPA released its RFI on July 31, with proposed modernizations to the Risk Management Programs (RMP) under the Clean Air Act (CAA). This RFI is part of the President Obama’s Executive Order (EO) 13650, Improving Chemical Facility Safety and Security, and EPA will use the information it receives in response to this RFI to inform what action it may take. The RFI also follows the U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA) RFI on Process Safety Management (PSM) modernization, which it released and ACA responded to on March 31, 2014. Of note, OSHA granted stakeholders an extension of its RFI comment period, which ACA underscored in its request to EPA.

Read on at:
http://paint.org/news/industry-news/item/1590-aca-asks-epa-for-comment-deadline-extension-on-rfi-for-risk-management-programs.html