ACD Press Release

ACD Submits Comments on EPA’s Reconsideration of the Clean Water Act Hazardous Substance Facility Response Plans

Arlington, VA –Yesterday, the Alliance for Chemical Distribution (ACD) submitted comments to the U.S. Environmental Protection Agency (EPA) as it reconsiders the Clean Water Act (CWA) Hazardous Substance Facility Response Plans (HSFRP).

In the comments, ACD Senior Vice President of Government Affairs Brian Callahan warned of the program’s broad scope and duplicative nature, which would place additional regulatory burdens on facilities already in compliance.

“While this new program intends to effectively improve the safety of facilities and surrounding navigable waters, we fear that, as written, it would significantly harm facilities with an overly broad scope and duplicative requirements. To best meet the Agency’s goals, we believe the EPA should focus this program on facilities that have the greatest potential for significant incidents and provide facilities covered by multiple programs with the opportunity to streamline duplicative regulatory obligations. This will make the most of the EPA’s resources and ensure the right facilities are scrutinized.”

Callahan also encouraged the EPA to reconsider the program implementation timeline.

“It is critical that in any future proposal the EPA issues to revise the CWA HS FRP program, the Agency consider further delaying compliance dates and provide the public with the opportunity to offer feedback on what delay may be appropriate.”

Callahan concluded, “We appreciate the EPA’s efforts to improve this regulatory program. ACD looks forward to the Agency’s proposal to amend this regulation.”

The chemical distribution industry cares deeply about preventing chemical incidents and mitigating their impact on the environment, which is why ACD members invest heavily in their facilities and regularly coordinate with local emergency officials to be strong stewards of their communities. Earlier this year, ACD applauded the EPA for listening to industry concerns regarding the program’s compliance deadline and for its willingness to address broader issues within the new regulatory framework.

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The Alliance for Chemical Distribution (ACD) partners with our more than 400 chemical distribution industry members to provide the education, connection, standards, and advocacy they need to responsibly move the essential products our world depends on. As leaders in the $27B+ chemical distribution industry, ACD member companies commit to the highest standards in quality, safety, sustainability, and performance through ACD Responsible Distribution^TM. For more information, visit www.acd-chem.com.

The American Fuel & Petrochemical Manufacturers (AFPM) is the leading trade association representing the makers of the fuels that keep us moving, the petrochemicals that are the essential building blocks for modern life, and the midstream companies that get our feedstocks and products where they need to go. We make the products that make life better, safer, and more sustainable — we make progress. For more information, visit https://www.afpm.org/.