COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE

The document argues that the EPA's 2026 proposed rule to weaken the Risk Management Program (RMP) is unlawful, arbitrary, and contrary to the Clean Air Act's mandate to prevent accidental chemical releases. The commenters contend that the proposal prioritizes industry cost savings and deregulatory executive orders over public health and safety, specifically threatening vulnerable populations and children. They call for the full implementation of the 2024 SCCAP Rule, the restoration of the RMP Public Data Tool, and the retention of critical safety requirements including safer technology analyses, third-party audits, and natural hazard planning.

• Over 177 million Americans, nearly half of the U.S. population, live in a "worst-case scenario zone" for at least one industrial chemical facility, and one in three schoolchildren attend school in these vulnerability zones.
• Between 2004 and 2025, industrial chemical incidents were reported to the EPA on average every other day, resulting in 113 deaths, 20,150 injuries or medical treatments, and 764,019 evacuations or shelter-in-place events.
• The EPA's 2026 proposed rule seeks to eliminate or significantly weaken the Safer Technology and Alternatives Analysis (STAA) requirements, which would reduce the number of processes subject to STAA evaluation by approximately 92% compared to the 2024 rule.
• The commenters argue that the EPA's reliance on an alleged decline in chemical incidents to justify deregulation is based on incomplete and under-reported data, noting that the agency missed at least 408 later-reported incidents from 2014 through 2023.
• The EPA removed the RMP Public Data Tool on April 18, 2025, without public notice; the commenters demand its immediate restoration and the codification of a regulatory requirement to maintain an online, updated public data tool including mapping and non-English translations.
• The proposed rule would rescind requirements for third-party compliance audits after a single incident, instead proposing to require them only after two incidents within five years, which the commenters argue is "too little, too late."
• The proposal seeks to remove critical worker participation protections, including training on employee participation plans, anonymous reporting systems, and stop-work authority, under the guise of "aligning" with OSHA PSM standards.
• The commenters oppose the proposal to weaken community notification requirements, which would shift the facility's responsibility from ensuring a notification system is in place to merely providing information to responders if a system already exists.
• The proposed rule would eliminate requirements for facilities to evaluate risks from natural hazards and power loss, despite evidence that climate change is increasing the frequency and severity of "NaTech" (natural hazard-triggered technological) disasters.
• The EPA is accused of violating the Clean Air Act by prioritizing industry cost savings and deregulatory executive orders (such as EO 14148, 14154, and 14192) over its statutory mandate to protect human health and the environment.
• The document asserts that the EPA failed to fulfill statutory requirements to consult with the Secretaries of Labor and Transportation and failed to satisfy Tribal consultation requirements for the proposed rule.
• The commenters argue that the EPA's proposal to broaden the definition of "retail facility" would unlawfully exempt more facilities housing flammable substances from RMP regulation.

APA

Earthjustice (2026). COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE. https://earthjustice.org/wp-content/uploads/2026/07/epa-hq-olem-2025-0313-0336_attachment_1-23.pdf

Chicago

Earthjustice. COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE. 2026. https://earthjustice.org/wp-content/uploads/2026/07/epa-hq-olem-2025-0313-0336_attachment_1-23.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE |date=11 May 2026 |url=https://earthjustice.org/wp-content/uploads/2026/07/epa-hq-olem-2025-0313-0336_attachment_1-23.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2026comments, author = {{Earthjustice}}, title = {{COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE}}, publisher = {Earthjustice}, year = {2026}, month = may, url = {https://earthjustice.org/wp-content/uploads/2026/07/epa-hq-olem-2025-0313-0336_attachment_1-23.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }