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On March 29th, the Environmental Protection Agency (EPA) held a public meeting to receive comments on its recently released proposed rule to amend the Risk Management Program (RMP) regulations. Lowell Randel, GCCA Vice President of Government and Legal Affairs, spoke to EPA officials regarding the cold chain industry’s concerns with the EPA proposals. His comments focused on the proposed requirements for facilities to conduct a third party audit after an RMP reportable accident. Randel stated that the current practice of allowing flexibility to use in house personnel to conduct audits should remain in place. He also expressed strong concerns that the proposed independence requirements of third party auditors are overly restrictive would lead to a shortage of qualified auditors with experience in industrial refrigeration facilities. He also addressed other concerns related to the definition of “near miss” triggering a root cause analysis and the proposed requirement to conduct a public meeting within 30 days of an accident. GCCA will be working with coalition partners to develop more detailed written comments. More information on the EPA’s proposed rule can be found here.