Colleagues,
On 13 January 2017 the U.S. EPA promulgated rules to strengthen risk management planning at high risk chemical facilities. My reading of these new rules is that they are reasonable and necessary, considering the fact that the current RMP program was not doing enough to prevent chemical accidents that endanger workers, neighbors and the environment. In early 2017, the new EPA administrator stayed the rule. On 17 May 2018 EPA formally proposed rescinding the new rules. EPA is requesting public comment now, which they are required to do by law. I encourage you to comment. For more information, see https://www.epa.gov/rmp/proposed-risk-management-program-rmp-reconsideration-rule
Further, if ACS cares about safety and the public's image of chemistry, ACS should file a formal comment as well. I hope that the ACS Office of Public Affairs is prepared, authorized and planning to do this. No student wants to major in chemistry with headlines like the one below.
I know that some people on this list are stridently anti-regulation and anti-policy. I suppose they would turn every highway in the U.S. into the autobahn, where every driver could choose their own "safe" speed limit. I, however, subscribe to the maxim often professed by our esteemed colleague Dr. George Wahl who says, "What the law does not require, common sense does not inspire."
Pete
Peter A. Reinhardt
Director, Office of Environmental Health & Safety
Yale University
135 College St., Suite 100
New Haven, CT 06510-2411
(203) 737-2123 peter.reinhardt@yale.edu
