"We all welcome the U.S. Environmental Protection Agency's (EPA) recently proposed Clean Air Act rule strengthening emissions monitoring and control requirements at EtO sterilization facilities We especially commend EPA for putting public health at the forefront of its considerations by conducting a residual risk review to support the proposal ... We also appreciate EPA's efforts to engage affected communities as it developed the proposed rule, and we urge EPA to make community engagement a core component of its process as it finalizes and implements the rule."
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"Given strong evidence that fence-line monitoring is a proven method for verifying the effectiveness of emission control equipment and detecting fugitive emissions, we encourage you to include requirements for fence-line monitoring in the final rule We ask that you clarify in the final rule whether offsite storage warehouses are covered facilities, and ask that the agency explore all regulatory options for addressing emissions from these facilities Given the dangerous risk EtO exposure continues to present to communities, we urge EPA to consider adopting a shorter compliance timeline in the final rule."