The National Association of Chemical Distributors (NACD) has submitted public comments in support of the Risk Management Program (RMP) Reconsideration proposed rule, which was signed by US Environmental Protection Agency (EPA) Administrator, Scott Pruitt, last month.The proposed rule is open for public comment until July 30.
What is the Risk Management Program (RMP)?
Broadly speaking, the RMP addresses potential security risks related to the handling or 
processing of hazardous chemicals and ensures adequate emergency planning in the event of an accident. The Program not only requires facilities to implement preventative measures that help avoid disasters but also necessitates that these facilities generate mitigation and containment plans so that they are prepared for worst case scenarios.
Details of the New RMP Proposed Rule
Under the Obama Administration, several amendments to the RMP were implemented in 2017. However, the proposed rule signed by Mr. Pruitt will modify several of those amendments. In describing the proposed RMP changes Mr. Pruitt stated that the “proposed rule will ensure proper emergency planning and continue the trend of fewer significant accidents involving chemicals,” while simultaneously “reduc[ing] unnecessary regulatory burdens, address[ing] the concerns of stakeholders and emergency responders on the ground, and sav[ing] Americans roughly $88 million a year.”
More specifically, the proposed rule aims to rescinds amendments that regulate third-party audits, incident investigations and safety standards for technology. Additionally, the proposed rule would delay the effective date of the 2017 amendments until February 19, 2019. Offsetting the effective date of the amendments will give the EPA sufficient time to consider and evaluate the various petitions and objections raised over the 2017 amendments and determine if alternative measures would be less controversial.
Since the EPA Administrator has signed the proposed rule, the NACD has expressed its support. In a statement released by NACD President, Eric Byer, the association commended the proposed rule, saying “we believe that with EPA’s release today of a new proposed RMP rule, many of the concerns we had with the previous proposal have been eliminated or addressed in a way that makes common sense.”
The proposed rule is open for public comment until July 30. A public hearing was held earlier this month. The full text of the proposed rule is available here.
