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ARTICLE · 03 APRIL 2025

The Future Of EPA's Risk Management Program May Be Found In History

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The U.S. Environmental Protection Agency ("EPA") announced it would reconsider the 2024 Risk Management Program ("RMP") rule.

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In Short:

The Situation: The U.S. Environmental Protection Agency ("EPA") announced it would reconsider the 2024 Risk Management Program ("RMP") rule.

The Result: EPA may revert to the same requirements from the first Trump administration's rule by rescinding the 2024 requirements for information availability and safer technologies and alternatives analyses, among others.

Looking Ahead: EPA will begin a new notice and comment rulemaking to clarify obligations under the RMP, likely before the compliance dates for the 2024 RMP rule.

Background

On March 12, 2025, EPA announced, among several pronouncements of deregulatory activity, its intent to reconsider the RMP rule enacted by the Biden administration (2024 Rule). Such an action would continue a tug-of-war over RMP requirements that has spanned multiple administrations.

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