Fri October 28, 2016

As the Obama Administration winds down, the Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) continue to advance rulemakings and related notices. The following were recently sent to the Office of Management and Budget (OMB) for review

  • Final rule, Modernization of the Accidental Release Prevention Regulations under Clean Air Act (RMP Rule; more here and SPI comments here)
  • Final rule, Clarification of Employer's Continuing Obligation to Make and Maintain Accurate Records of Each Recordable Injury and Illness (“Volks II” decision; more here). This proposal would seemingly circumvent a court decision upholding the current statute of limitations from an alleged violation of an OSHA standard to the time of a citation as six months; OSHA seeks to be able to issue citations for records violations as far back as five years.
  • Notice, Financial Responsibility Requirements under CERCLA Section 108(b) for Facilities in the Chemical, Petroleum and Electric Power Industries (more here)
  • Final rule, Greenhouse Gas Reporting Program – General Revisions (more here)

Separately, EPA reopened the comment period on its July 28 proposal to align existing regulations governing significant new uses of chemical substances under the Toxic Substances Control Act (TSCA) with revisions to OSHA’s Hazard Communications Standard (HCS), changes to the OSHA Respiratory Protection Standard, and to certain National Institute for Occupational Safety and Health (NIOSH) respirator certification requirements. Other proposed changes address the significant new uses of chemical substances regulations and reporting requirements for certain TSCA section 5 notices (e.g., premanufacture notices). Comments must now be received by November 21.

For more information or to engage with SPI’s EHS+ Committee on these items, please contact Marie Gargas


Founded in 1937, SPI: The Plastics Industry Trade Association promotes growth in the $427 billion U.S. plastics industry. Representing nearly one million American workers in the third largest U.S. manufacturing industry, SPI delivers legislative and regulatory advocacy, market research, industry promotion and the fostering of business relationships and zero waste strategies. SPI also owns and produces the international NPE trade show. All profits from NPE are reinvested into SPI’s industry services. Find SPI online at

"From resin suppliers and equipment makers to processors and brand owners, SPI is proud to represent all facets of the U.S. plastics industry," said William R. Carteaux, president and CEO, SPI. "Our most recent economic reports show that the plastics industry as a whole is resilient, and has come through the recession significantly better than other U.S. manufacturing sectors."