By: Vanessa Lynch, Pennsylvania Campaign Coordinator, Moms Clean Air Force
Date: March 10, 2026
About: EPA Docket ID No. EPA-HQ-OLEM-2025-0313
To: Environmental Protection Agency
My name is Vanessa Lynch, and I am the Pennsylvania Campaign Coordinator for Moms Clean Air Force. I am here today representing the over 107,000 caregivers across Pennsylvania united to fight air pollution and protect our children’s health.
The proposed changes to the Risk Management Program threaten the lives and safety of the over 177 million Americans who live in worst-case scenario zones near chemical facilities. The proposal increases the likelihood of chemical emergencies and disasters for workers, first responders, and children and families who live within a chemical danger zone. I urge EPA to maintain essential requirements of the plan that protect the health and safety of communities near these facilities.
One of the largest petrochemical complexes in North America can be found in Pennsylvania—Shell Polymers Monaca. Since September 2022, the facility has had at least 80 total malfunctions including 4 high priority events in the last year alone. The National Chemical Safety Board is investigating a high priority event from last summer when a fire and chemical release of benzene and 1, 3 butadiene occurred. Benzene is classified by EPA as a Category A known human carcinogen linked to leukemia.
For those living near chemical facilities we know that exposure to harmful chemicals can worsen respiratory and other health conditions. Over one in every three school children in the U.S. (36% of pre-kindergarten through high school students) attends a school within the vulnerability zone of a hazardous chemical or petrochemical facility. Half of these children are in schools located in MORE than one chemical vulnerability zone. According to the Pennsylvania Department of Health’s 2025 statistics, almost 1 in every 10 children in Pennsylvania suffer from asthma, making their likelihood of having reactions to their proximity to these chemical facilities greater.
Additionally, the EPA needs to require Risk Management Program facilities to incorporate climate and natural disaster risks into their plans and have plans to address any associated loss of power. Many Risk Management Program facilities throughout the United States are in areas that are seeing increasing impacts from climate change, such as coastal flooding, inland flooding, wildfires, and storm surge. A Union of Concerned Scientists study and report from 2021 found that roughly a third of Risk Management Program facilities are at increased risk from climate impacts.
For these reasons, I urge EPA to maintain the essential requirements of the plan that protect the health and safety of Pennsylvania communities and families near these facilities.