In comments filed last week with the Environmental Protection Agency (EPA), IDFA supported proposed changes to the agency’s 2017 Risk Management Plan (RMP) rule that would reduce unnecessary regulatory burdens and address the concerns of stakeholders and emergency responders. The RMP rule regulates the dairy industry’s use of certain chemicals in refrigeration systems and wastewater treatment.

IDFA was engaged in the prior RMP rulemaking process, raising concerns about the rule’s unnecessary burdens on the dairy industry. The revisions included in the agency’s most recent proposed rule address many of these concerns, IDFA said.

“If EPA makes the necessary improvements to the regulation, the RMP program will adequately protect the public from chemical accidents while placing a lesser burden on our members and avoid the costs associated with complying with the flawed amendments,” the association said in the comments.

IDFA specifically supported EPA’s suggestions that would:

• Address procedural and factual flaws in the prior rulemaking to ensure a fully considered and accurate rule;
• Ensure that the rule will not overlap with similar regulations issued by the Occupational Safety and Health Administration and the Department of Homeland Security;
• Rescind many of the program requirements that do not result in increased safety or reduce incidents, such as third-party audits;

• Withdraw information-availability requirements that could jeopardize facility security;
• Maintain requirements for coordination between facilities, local emergency planning committees and emergency responders;
• Change the frequency of emergency response exercises; and
• Maintain requirements for companies to update emergency response plans with findings from safety drills.

Read the comments here.

For more information, contact Danielle Quist, IDFA senior director of regulatory affairs and counsel, at dquist@idfa.org.