Official Comment on The Proposed Risk Management Program Revision
Risk Management Program: A Common-Sense Approach to Chemical Accident Prevention
In 2026, the U.S. Environmental Protection Agency released a proposed rule to revise the Risk Management Program (RMP), a regulation under the Clean Air Act that applies to facilities handling the most hazardous chemicals and substances, known as RMP facilities. These facilities must have information on: “off-site consequences,” such as the potential effects of a chemical release and their impact on the surrounding community; a plan to prevent chemical disasters; and an emergency plan for when chemical disasters or incidents occur. These plans are required to be provided by owners of RMP facilities to the public upon request.
There are more than 12,000 RMP facilities in the United States, with more than 250 in the Greater Houston Area alone. One RMP facility here in Houston’s East End manufactures sulfuric acid and operates less than a mile from three public schools and is one mile away from an RMP-regulated refinery. If this sulfuric acid plant experienced its worst-case scenario, the result would be a catastrophic toxic air cloud extending 25 miles in all directions, reaching as far north as Spring, TX, and as far South as Rosharon, impacting over 4 million people. This event would create a domino effect with surrounding facilities, both RMP and non-RMP. Even if you don’t share a fence with these facilities as we do, you can still be affected.
Understanding the impact these rollbacks would have on Houston Ship Channel communities. Fenceline Watch initiated visiting hard-to-access reading rooms to understand potential impacts. On May 11, 2026, we formally submitted a public comment to the U.S. Environmental Protection Agency to stop the planned rollbacks of the Risk Management Program. This has led to a series of community workshops on the potential impacts of these facilities and how to prepare before disaster strikes.
It’s critical that RMP facilities nationwide have regulations that prioritize community protection. As community members, we have a right-to-know the risks these facilities present and to understand the impact of the Risk Management Program rollbacks on communities.
Some highlights (read our full comment):
Backup Power Systems and Consideration of Natural Disasters in RMP
Hurricane season begins June 1 and runs through November 30th, half of the year. Meteorologists have called for a new Category 6 Hurricane classification due to the increasing intensity of weather events. The effects of human-induced climate change are causing more extreme weather (extreme rain, wind, and increased lightning) outside of hurricane seasons. Being located along the Houston Ship Channel, we can attest to the increase in events that result in power outages. We need RMP to continue to require facilities to have a backup power plan in place and not rescind this in their proposed changes. When facilities experience a power outage, they often emit higher levels of chemicals than they are legally permitted. These backup power systems would maintain air quality monitoring systems, must to ensure they remain active during these high-emission events.
Community Participation and Access to Information
Our communities live in a state of petro-terrorism, and understanding the dangers these lethal neighbors have on our lives drives us to demand the right to access information on RMP facilities that affect us. This includes the availability of information in the languages we speak. Our communities rank in the 96th- 97th percentiles nationally for limited-English-proficient speakers, approximately 30 million individuals in our state, and an estimated 10 million people speak a language other than English at home.
Employee Protection
Workers are at ground zero at these dangerous facilities. When leaks or issues occur, workers are exposed to high concentrations of potentially lethal chemicals. Workers currently have the authority to issue stop-work orders to prevent catastrophic events. The RMP must maintain key whistleblower protections so workers can anonymously report hazardous conditions without fear of intimidation or retaliation. Changes to the RMP could remove these provisions and force workers into dangerous positions at the hands of their employers. Workers should have the right to participate in worker participation plans and to be trained on how to report violations or noncompliance.
Safer Technology and Alternative Analysis (STAA)
In the Greater Houston Area, there are nearly 700 chemical facilities that frequently experience upsets such as fires, explosions, and leaks. The RMP must continue to consider Safer Technology an Alternative Analysis (STAA).STAA is intended to analyze a facility’s current processes and practices to identify safer alternatives, such as using less hazardous chemicals, fortifying blast walls, and installing vapor detection systems. Currently, owner/operators of qualifying RMP facilities must consider STAA analysis in their risk planning.
Third-Party Compliance
Repeated violations of the Clean Air Act and accidental emissions are red flags that a facility’s processes may be outdated and potentially dangerous. The proposed change would require a facility to have two accidents before a third-party compliance audit is triggered. Although the agency states this as onerous, vulnerable communities would be forced to shoulder repeated health impacts, externalizing costs to the general public. State agencies such as the Texas Commission on Environmental Quality should have the right to request a third-party compliance audit if conditions at the plant could lead to a catastrophic release. We argue that a third-party should audit an RMP facility if it has done any of the following:
Violated the Clean Air Act for four consecutive quarters
Had an emissions event that required a shelter-in-place within 3 miles in the last five years
Had an accidental release of a regulated process and regulated substances within the previous 12 months
