The Trump administration is renewing its focus on deregulation, with potential rollbacks that could significantly affect the natural refrigerant and broader chemical safety industries.

“The Trump administration is making deregulation a priority, and the goals are to reduce the number of regulations and reduce the cost of regulations. It’s part of a broader effort across government, and some changes will have a direct impact on IIAR members,” said Lowell Randell, director of government relations for IIAR. “We don’t have many details on anything yet. It is all prospective and potential, but we can get clues from what happened in the first Trump administration.”

Risk Management Program Under Review

Environmental Protection Agency Administrator Lee Zeldin announced that the agency is going to reconsider more than 30 rules, including the Risk Management Program (RMP). “There’s no more detail than that on exactly what they’re going to propose for reconsideration,” Randell said.

Originally introduced in 1996, the RMP was significantly expanded during the Obama administration. These measures were rolled back during Trump’s first term, only to be reinstated and strengthened under President Biden in 2021. The Biden-era rules aimed to reduce the risk of industrial accidents at nearly 12,000 high-risk facilities, such as oil refineries, chemical plants, and water treatment sites. They also called for increased transparency with local communities and emergency responders, independent audits for facilities with a history of accidents, and a review of the most dangerous chemicals used, encouraging safer alternatives where feasible.

The enhanced rules required stronger protections against spills, explosions, and climate-related disasters like floods and hurricanes. They also mandated greater transparency with local communities, independent safety audits, and a shift toward safer chemical alternatives. The EPA plans to rewrite the regulation.

EPA filed a motion in federal court indicating it intends to rewrite the regulation. Challengers argued that the new requirements imposed significant costs and compliance burdens without delivering proportional safety benefits.

“We know that the Trump administration has identified climate-change related provisions and DEI or environmental justice provisions across government as being counter to its position,” Randell said. “So, inasmuch as there are some pieces of the RMP rule that Biden put forward that get kind of into those territories, I would anticipate that they will take a close look at things like the natural hazards provisions, the facility siting, and related provisions.”

There may also be more review of programmatic policies, such as safer technology analysis, as well as operational provisions, like hot work permits. Randell said there isn’t a timeline for the review. “When you announce that you’re going to be reconsidering 30 different rules, some of them were going to go quicker than others, and we don’t know where RMP is going to fall in that timeline,” he explained. “We may see things happen in the next several months, or depending on where they prioritize their quickest actions, it might come a little bit later in the Trump administration.”

Clean Water Act Rule May Be Revised

Another regulatory requirement that may change is the Clean Water Act Worst Case Discharge Planning Rule. “This applies to facilities that are within a particular radius of a protected waterway,” Randell explained.

The rule applies to facilities that have more than 100,000 pounds of ammonia and are located within 0.5 miles of a navigable water or a conveyance, such as a ditch or storm drain, that can reach navigable water. Currently, the compliance date is June 1, 2027.
“It is being looked at by EPA and may become one of those areas where they take some type of action, whether it is revising the rule or extending compliance dates,” Randell said.

Uncertainty Around the AIM Act

Key provisions of the American Innovation and Manufacturing (AIM) Act are also being reconsidered. The EPA recently signaled its intent to review the Technology Transitions rule, specifically increasing the global warming potential (GWP) threshold for new cold storage refrigerants from 150 to 700.

EPA and Congress are currently reviewing key parts of the American Innovation and Manufacturing Act. The U.S. Environmental Protection Agency has announced plans to reconsider the Technology Transitions rule, including changing the new cold storage refrigerant GWP from 150 GWP to 700 GWP. Read more about uncertainty surrounding the AIM Act on page XX.

Tristam Coffin, co-founder and president, sustainability, policy and technical services, êffecterra, said the industry, including OEMs and others, has largely been in favor of the technology transition. “There is a holistic perception that regulation is bad for business, and that’s not always true. In this instance, industry has largely been behind the Technology Transition rule,” he said.

Certain timelines in the rule were already delayed once from the proposed rule to the final rule, and those in the industry have been preparing to meet the deadlines. Having to retool now or make further adjustments doesn’t necessarily benefit the OEMs. “If there’s going to be
regulation, folks want consistency,” Coffin said.

Deregulation at the federal level could push states to adopt their own restrictions, explained Danielle Wright, executive director of the North American Sustainable Refrigeration Council (NASRC). Some states, including California and New York, already enforce strict GWP standards. “The reality is that the majority of end-users would prefer to have consistent and predictable regulations, rather than deal with a patchwork of state regulations,” she explained. “Uncertainty is not good for business.”

Companies operating within the U.S. and internationally are already dealing with differences in regulations. “Now you enter local and state regulation, and it becomes even more challenging for them,” Coffin said.
Even if limits are changed and larger quantities of synthetics are allowed, many of the new synthetic refrigerants present other environmental challenges, such as being classified as PFAS, which may also face new regulatory requirements. “In my mind, all of the potential pros and cons of these solutions need to really be laid out,” Coffin said. “A lifecycle analysis approach needs to be taken to determine the best overall solutions.”

Currently, the California Air Resources Board is working with several partners to develop a life cycle analysis of synthetic and natural refrigerants. “I think that will be really telling,” Coffin said. “We’re also working on an embodied carbon methodology for commercial refrigeration equipment, for example, which I think is another important factor in choosing the winners through the lifecycle lens.”