To VI HSE Committee,
As you know, EPA delayed the effective date of its changes to the Agency’s Risk Management Program (RMP) until February 19, 2019. EPA asked for comments on this delay per the attached Federal Register notification. The VI filed comments on Friday, May 19, 2017 to EPA’s docket on the subject. VI’s comments are attached along with our previous two submissions on this rulemaking. In short, we advocate that EPA take the time during the delay to reconsider a number of the new requirements in the RMP that may not enhance safety but may put security at risk. Please advise if you need any specific information with respect to the rulemaking or if you would like VI to take further action. Your comments or questions are appreciated.
Regards,
Rich
Additional Resources
EPA RMP Delay_of_Effective_Date_Pruit FR 04-03-2017
VI Comments on RMP Proposal – Submitted 05-13-2016
VI Comments to EPA on RMP Implementation Delay submitted 05-19-17