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Regulatory Report on Oil Dispersants

Our new regulatory report offers guidance on how the EPA can improve its cost-benefit analysis for a new proposed rule regulating the dispersants used to clean up oil spills and other major pollution events. In January 2015, the EPA proposed revisions to the National Oil and Hazardous Substances Pollution Contingency Plan, which provides oversight for pollution response efforts. In its proposed rule, the EPA added new listing criteria for oil dispersant ingredients, revised efficacy and toxicity testing protocols, and clarified the evaluation for removing products from the required schedule, among other changes. The proposed regulation is designed to ensure that chemical and biological agents used in cleanup efforts meet efficacy and toxicity requirements and that, through the listing process, the pollution response community and dispersant consumers have sufficient information to make informed decisions. We submitted this regulatory report to the EPA as our public comments on the proposed rule.

The regulatory report outlines a series of suggested changes to strengthen the proposed rule and its economic analysis, including:

  • EPA should quantify and monetize the rule’s benefits and costs to the extent feasible;
  • EPA should more clearly describe the qualitative costs and benefits of the rule; and
  • Strong ingredient disclosure policies should be used, given that companies have disclosed ingredients in analogous regulatory contexts.

We believe that this rule could help increase transparency and stimulate innovation.