TRAA Seeking Letters of Support & Comments to EPA by July 31 Deadline

As part of the national effort to phase out HF in refineries, TRAA has submitted a proposed amendment to the EPA Risk Management Plan (RMP) Rule CFR 40 Part 68. The objective of TRAA’s amendment is to force conversion from HF to a vastly safer alternative.

On January 20, 2021, President Biden issued E.O. 13990, which directed federal agencies to review existing regulations and take action to address priorities established by the Biden administration. The EPA responded by undertaking a revision to its Risk Management Plan regulations (40 CFR part 68 – Chemical Accident Prevention Provisions) to minimize public impacts of accidental releases of highly hazardous chemicals.

We’re asking your help in submitting a comment and letter to the EPA in support of TRAA’s proposed amendment. These will be read by EPA staff as they write a revised Rule — due out in September 2021. Submitting your or your organization’s thoughts and any additional data or information will be invaluable in the effort to protect communities from a catastrophic release of HF.


We’ve prepared a kit to help you submit your comments. Click the links in the four items below to assist you:

  1. TRAA’s proposed amendment to CFR 40 part 68.
  2. A list of 12 arguments for converting HF to a safer alternative technology — pick one or two and weave them into your letter which can be attached to your comment.
  3. A letter submitted to the EPA by former EPA administrator and New Jersey governor Christine Todd Whitman, retired generals Russel Honoré and Randy Manner, former EPA official Robert Bostock, and David Halperin calling for similar changes.
  4. The start of an optional support letter, which you can download to assist your writing. Organizations: please submit on your letterhead.
Submit your comment and optional supporting letter and other materials to the EPA by clicking here.

See EPA’s Tips for Effective Comments for useful guidance. The EPA will send an email back to you with your submittal. Please forward it to