March 4, 2024
PUBLIC STATEMENT: EPA RISK MANAGEMENT RULE
The Environmental Protection Agency (EPA) finalized a Risk Management Program (RMP) rule that will further impede job creation, industry growth, reshoring of manufacturing, and securing the supply chain with a rule that lacks justifiable improvements to prevention of accidental releases. The rule includes:
- Safer Technology and Alternative Analysis (STAA) – In a batch facility where manufacturing processes are short runs and not necessarily run consistently, the resources used to conduct an STAA do not contribute to a measurably safer outcome. Given that a single batch process may be run for a matter of days, while the process of conducting an STAA could take weeks, the process in question may no longer be in use at the facility by the time the STAA is completed.
- Information Disclosures – SOCMA members make safety their highest priority and work closely with Local Emergency Planning Committees (LEPCs). SOCMA members provide LEPCs and the public with all the information necessary to understand the hazards at facilities and to prepare for and respond to releases. This proposal does not provide adequate protections against disclosure based on considerations of security and protection of confidential business information.
- Third-party Audits – The most effective audit for a batch manufacturing facility is an internal audit given that most third-party auditors have no immediate understanding of the unique operating specifications and processes at batch-manufacturing facilities, leading to an unproductive audit.
“The Risk Management Program Final Rule creates subjective standards and forces facilities to waste resources that could otherwise be applied to process safety improvement or increase site security,” said Robert Helminiak, SOCMA’s VP of Legal and Government Relations.
Additionally, specialty chemical manufacturers are not properly considered with Safer Technology and Alternative Analysis and Third-Party Audit provisions. These are high cost and resource intensive compliance requirements, which do not necessarily lead to improved mitigation of accidental releases for batch manufacturers.”
Contact government.relations@socma.org for more information on the Final Risk Management Program Rule.
About SOCMA
Solely dedicated to the specialty and fine chemical industry, the Society of Chemical Manufacturers & Affiliates® (SOCMA) builds commercial connections, supports safe manufacturing and operations, and advocates for regulatory and legislative policies for the batch and specialty chemical sector. Our members play an indispensable role in the global chemical supply chain, providing specialty chemicals and services to vital markets ranging from aerospace and electronics to pharmaceuticals and agriculture. For more information on the association, visit https://www.socma.org.