In comments filed last week with the Environmental Protection Agency, IDFA said the agency’s final amendments to its Risk Management Program (RMP) fall short of their intended goals, will have a negative impact on the dairy industry and should be delayed and revised. While IDFA supports efforts to modernize and streamline RMP regulations, which regulate the industry’s use of chemicals in refrigeration systems and wastewater treatment, these proposed amendments will not help to prevent chemical accidents or minimize their impact on communities.
Last month, EPA issued a proposal to delay implementation of the amendments from June 19 of this year to Feb. 19, 2019, to allow the agency more time to consider petitions and possible revisions submitted in comments from stakeholders.
In comments, IDFA supported the delay and suggested several areas for EPA to examine, including:
- Requirements to share information with the public that could increase the threat of sabotage or vandalism and result in chemical accidents;
- Coordination and emergency response requirements that impose significant burdens on local emergency planning committees and local emergency responders;
- Overly burdensome audit requirements, hindering the ability of dairy companies to find qualified, competent and independent auditors to audit their ammonia refrigeration systems; and
- Provisions that overlap and are inconsistent with the Occupational Safety and Health Administration’s Process Safety Management regulations and the Department of Homeland Security’s Chemical Facility Anti-Terrorism Standard, which some dairy companies must also comply with.
IDFA also expressed concern that EPA rushed to finalize the rule, basing it on last-minute documents added to the docket after a hurried public comment period. EPA also did not adequately consider the level of new burdens that the amendments would place on small companies.
IDFA’s full comments can be found here.
For more information, contact Emily Lyons, IDFA director of regulatory affairs and counsel, at email@example.com.