Government Activity
The Chlorine Institute is actively engaged in the regulatory process and representing members on issues that affect the chlor-alkali industry. CI is also a member of the Chemical (Security) Sector Coordinating Council and has provided support in the Jack Rabbit release trials, sponsored by DHS.
Chemical Safety Board (CSB)
CSB’s exhaustive investigations and root cause analyses provide lessons learned for the entire chemical industry. CI has been both the recipient and beneficiary of CSB recommendations from past investigations. Click here to view details on how CI successfully resolved CSB recommendations after appropriate enhancements were made in various pamphlets.
CI Comment Letter on CSB Accidental Reporting Rule | CSB's Call for Comments
Department of Homeland Security (DHS)
TWIC Reader Rule Stay Order | Government Response to Stay Order
Brief Background on TWIC Reader Rule Litigation: Coalition Letter Urging Action on TWIC Reader Rule - November 20, 2017
TWIC Next Generation Card Design Guide (members only)
CI’s Comments on Personnel Surety for Tiers 3 and 4 | DHS’s Call for Comments
Nov. 2020 Special Edition of the peer-reviewed Journal of Atmospheric Environment features over a dozen articles on chlorine dispersion models with insights from the DHS-led, years-long large-scale chlorine release trials, often referred to as the Jack Rabbit project.
Environmental Protection Agency (EPA)
CI regularly participates in EPA’s rulemaking process, and this falls under both the HESS and Product Stewardship Issue Teams. For issues related to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and EPA’s Safe Drinking Water Act, please visit the Stewardship Government Activity Page.
Risk Management Program (RMP)
US Court of Appeals - RMP Delay Rule Decision To Vacate - August 2018 *members-only, highlighted version
CI Comments on Delaying Implementation of RMP Rule
Summary of Final RMP Rule Released January 13, 2017 *member login required
Final RMP Rule Released January 13, 2017 | RMP Effective Date Extension
Proposed Changes to RMP Webinar Video | RMP Webinar PowerPoint Slides *member log-in required
CI Comments on EPA’s RMP Notice of Proposed Rulemaking (NPRM), March 2016
CI Comments to EPA's RMP RFI | EPA RMP RFI July 31, 2014
Toxic Substances Control Act (TSCA)
Problem Formulation of the Risk Evaluation for Asbestos, Chlor-Alkali Sections Highlighted | Problem Formulation of the Risk Evaluation for Asbestos on EPA’s Website
CI Comments on EPA’s Scope of the Risk Evaluation for Asbestos (Sept. 2017) | EPA Call for Comments on Scope of the Risk Evaluation for Asbestos
CI Comments on Asbestos Risk Evaluation Scoping Efforts (March 2017) | EPA Call for Comments on Asbestos Risk Evaluation Scoping Efforts
Summary of the Frank R. Lautenberg Chemical Safety for the 21st Century Act
Occupational Safety & Health Administration (OSHA)
Call for Comments – Indoor and Outdoor Heat Injury and Illness Prevention Advanced Notice of Proposed Rulemaking (ANPRM) | CI’s Submitted Heat ANPRM Comments
Call for Comments – Process Safety Management (PSM) Small Entity Representative Issues Document | CI’s Submitted Comments on SER Document
OSHA’S Tracking of Injuries & Illness Final Rule: What You Need to Know Webinar Video | OSHA Recordkeeping Rule Webinar Slides *member log-in required
Hydrochloric Acid and PSM Coverage: CI’s Inquiry | OSHA’s Response | OSHA’s July 2016 Memo
OSHA Interpretation - PSM RAGAGEP: New 2016 Memo | Summary Infographic