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ACD Press Release

Arlington, VA
October 31, 2022

Susannah Williams

NACD Submits Comments to EPA on Proposed Changes to Risk Management Plan Rule


Arlington, VA – Today, the National Association of Chemical Distributors (NACD) submitted comments to the U.S. Environmental Protection Agency (EPA) urging the agency to reconsider its proposed changes to the Risk Management Plan (RMP) rule.

In the comments, NACD Vice President of Regulatory Affairs Jennifer Gibson highlighted the effectiveness of the current RMP rule at preventing chemical accidents and urged the agency to reconsider its blanket requirements on all businesses, including those already in compliance.

“Instead of requiring new regulations for all facilities covered by RMP, the EPA should focus on facilities that are noncompliant and/or experiencing the majority of accidents,” wrote Gibson. “NACD urges the EPA to focus its efforts on these facilities instead of broadly applying new regulations to all RMP facilities, the vast majority of which are in compliance and have successfully prevented accidental releases.”

Gibson also raised concerns over the unnecessary and burdensome regulations that will place additional strain on chemical distributors, particularly small businesses.

“Furthermore, when assessing the costs of the proposal, it appears that ensuring compliance will be costly to businesses,” stated Gibson. “Considering these costs, in addition to the labor hours and administrative costs attached to other provisions of this proposal, NACD members estimate that the cost per facility could easily exceed $100,000 per year.”

Gibson concluded, “Creating a final rule that adds additional requirements may result in facilities defunding important and proven mitigation resources to ensure they can finance these new provisions. NACD urges the EPA to withdraw the proposed rule and allow the current RMP regulations to continue to operate successfully.”

To read NACD’s full comments submitted to the EPA, click here.

On August 22, 2022, NACD President and CEO Eric R. Byer released a statement voicing concern with the EPA’s proposed changes to the RMP rule.

On July 26, 2021, NACD responded to EPA’s request for comment on revisions to the RMP program to underscore the impacts of this potential change. Those comments are available here.  


NACD and its over 400 member and Affiliate companies are vital to the chemical supply chain providing products to over 750,000 end users. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and a third party-verified management practice. For more information on NACD, visit