American Chemistry Council

• RMP has been, and will continue to be a positive experience.

• DOJ/EPA final rule reinforces the RTK institutional infrastructure created by EPCRA.

• OCA on the Internet is representative of information stewardship concerns facing government.

RMP: Positive Experience

• Process safety management improvements.

• Opportunity for community interaction.

• Strengthened LEPC/facility relationship.

• Improved data: 5 year accident history

RTK Infrastructure

• Final rule “encourages” LEPCs to provide access to OCAs.

• Provides flexibility for LEPCs:– To determine if there is a demand– How to make the data available– Registration procedures

Information Stewardship

• EPA was placed in a difficult position.

• EPA’s tendency is to be pro RTK. Make all information available. Which is good.

• But information collection can have impact beyond EPA’s scope.

• Thus, a process is needed.

Information Stewardship