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The American Chemistry Council (“ACC”) submitted October 31st comments to the United States Environmental Protection Agency (“EPA”) on its proposed revisions to the Clean Air Act Risk.

United statesLacks statutory authority toClean air act risk management programCannot delegate any authority it mayDevelopment phases of newParty auditsParty auditing is necessarySafer technologyParty compliance auditsUnited states environmental protection agencyLacks statutory authority to require thirdAmerican chemistry councilParty audit recommendations could impermissiblyClean air actNot demonstratedLink between natural hazards