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Ted Strotter’s Full Comment to the U.S. EPA

I appreciate this opportunity to speak on the proposed effective date of the 40 CFR Part 68 Risk Management Program (RMP) Rule final amendments. While I only recently became aware of this rule I feel I can lend some insights into its importance. I spent almost 35 years at a large international manufacturing facility as a chemical & environmental safety engineer. I was also the site coordinator responsible for compliance with OSHA’s 1910.119 Process Safety Management of Highly Hazardous Chemicals, as well as the chemical advisor for our site hazmat team and received yearly training as required by OSHA’s 1910.120 Hazardous Waste Operations and Emergency Response regulations.

The in depth process safety analysis of chemical operations required by 1910.119, as well as a number of its other requirements, are similar to what is required in EPA’s RMP Rule. In addition the RMP Rule puts much emphasis on looking at the impact of worst case scenarios & coordinating emergency response with local fire companies, etc. All my colleagues on the emergency response team at the plant I worked at, some who were also active outside work as fire fighters and EMTs, would agree that emergency preparedness is the key to minimizing the impact of chemical incidents.

So what happens if we continue to delay this regulation? Essentially we will continue to put off critical worse case scenario planning which can save lives and property damage in the event of such a scenario, which will continue to happen as they have in the past. I have reviewed comments from safety/health/environmental personnel and from engineers & management representing industry concerns. It is imperative that regulators understand the difference in perspective between these two groups. The former’s primary concerned is with protecting personnel and the environment, while the latter is concerned with the bottom line of producing as much product as possible at the lowest possible cost.

While I worked at a company that stressed the importance of safety/health/environmental issues, I was many times at odds with the engineers and management of the chemical processes they were responsible for as my requirements for safety equipment and/or procedures would cost money and possible delays in getting their new or updated processes online & making the company money. The engineers and management were good people but their advancements and raises were contingent on enhancing the company’s bottom line.

I found that I could always win my argument for safety equipment and procedures if I could show that they were required by regulation. This was especially true if the fines were sufficient to get upper management’s attention.

So do we want to listen to those whose primary responsibility is the protection of personnel and the environment or those whose primary responsibility is the bottom line, in which case we will continue to have preventable accidents and have to explain to family and friends why their loved ones were killed or injured. This is not about protecting jobs and economic growth, this RMP Rule is about protecting lives. Protecting lives is part of EPA’s mission statement as shown by this quote from their website: “The mission of EPA is to ensure that all Americans are protected from significant risks to human health and the environment where they live, learn and work.”

Please do not delay the implementation of the RMP Rule any further.

– Ted Stroter, retired chemical and environmental safety engineer

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