The Natural Refrigeration

On July 4th, 2026, the Trump Administration released its updated Unified Regulatory Agenda for 2026. The Regulatory Flexibility Act requires federal regulatory agencies to publish their regulatory plans on a semiannual basis. The target dates for release are April and October, but historically administrations have not always followed that timeline. The July 2026 release appears that it will cover all of 2026 and be the only update provided this year. The Regulatory agenda lists all “active”, “completed” and “long-term” regulatory actions within an agency.

In addition to the regulatory agenda, the Administration also published an accounting of deregulatory actions taken in fiscal year 2025 carried out under Executive Order (EO) 14192. The order requires federal departments and agencies to: (1) issue 10 deregulatory actions for each new regulatory action; and (2) not exceed a regulatory cost allowance. For fiscal year 2025, agencies were directed to ensure that the total incremental cost of all new regulations finalized is significantly less than zero.

According to the Administration, agencies have far exceeded the 10 for 1 requirement in 2025. The report indicates that the ratio in 2025 was 129 to 1. Agencies issued 646 deregulatory actions and 5 significant regulatory actions. Within these results, Agencies issued 218 deregulatory actions that delete, modify, or otherwise refine the Code of Federal Regulations, which reflects a 43 to 1 ratio. The report further states that regulations eliminated in 2025 will save about $211.8 billion in present and future regulatory costs across the government.

The 2026 Unified Regulatory Agenda contains 3,954 agency actions across the federal government including 2,518 active actions, 628 completed actions, and 808 long-term actions. A total of 1,119 actions were published in the Unified Agenda for the first time, a majority of which are considered deregulatory in nature.

Below is a summary of selected Regulatory Agenda items for the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) that could impact IIAR members:

EPA Agenda Items

Title: Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Common Sense Approach to Chemical Accident Prevention

Abstract: The EPA is undertaking a rulemaking to amend its Risk Management Program (RMP) regulations by making several proposed changes to the 2024 Safer Communities by Chemical Accident Prevention rule. The proposed amendments will seek to improve chemical process safety by avoiding duplicative requirements, realigning RMP requirements with Occupational Safety and Health Administration (OSHA) Process Safety Management requirements, and eliminating unnecessary burdens placed on facilities where there is not specific data available to show that the current RMP standards would reduce or have reduced the number of accidental releases.

Status: The Proposed Rule was published on February 24, 2026. The public comment period ended May 11, 2026. IIAR provide both oral and written comments. The target date for publishing a Final Rule is in September 2026.

Title: Risk Management Program, CAA section 112(r)(7)(Section 610 Review) Abstract: EPA is initiating a review of the 2017 Risk Management Program (RMP) final rule (82 FR 4594) pursuant to section 610 of the Regulatory Flexibility Act (RFA, 5 U.S.C. 610). Since 2017, the Agency has published two additional final rules for the Risk Management Program on December 19, 2019 (84 FR 69834) and March 11, 2024 (89 FR 17622). Section 610 of the RFA requires that federal agencies review each rule that may have a significant economic impact on a substantial number of      small entities within ten years of publication of the final rule. EPA initiates a Section 610 review to determine if the provisions of a rule that are related to small entities should be continued without change, rescinded, or amended to minimize adverse economic impacts on small entities. Section 610 review of the 2017 rule is unrelated to the rulemaking entitled Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Common Sense Approach to Chemical Accident Prevention.

Status: EPA initiated its review in July 2026 and it is targeted for completion in early 2027.

OSHA Agenda Items

Title: Lock-Out/Tag-Out Update

Abstract: Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with the Occupational Safety and Health Administration’s (OSHA) existing lock out/tag-out (LOTO) standard. The use of these computer-based controls has become more prevalent as equipment manufacturers modernize their designs to increase productivity. Additionally, National Consensus Standards have evolved, and international approaches to the use of computer-based controls are increasingly recognized. In light of these advancements, there is a need to modernize United States regulations to better align with current technologies, ensuring improved safety effectiveness and, indirectly, potential benefits such as increased operational efficiency. OSHA issued a Request for Information (RFI) in May 2019 to understand the strengths and limitations of this new technology, as well as potential impacts on worker safety.

Status: A Notice of Proposed Rulemaking is targeted for release in November 2026.

Title: Emergency Response Abstract: OSHA currently regulates aspects of emergency response and preparedness; some of these standards were promulgated decades ago, and none were designed as comprehensive emergency response standards. Consequently, they do not address the full range of hazards or concerns currently facing emergency responders and other workers providing skilled support, nor do they reflect major changes in performance specifications for protective clothing and equipment. The agency acknowledges that current OSHA standards also do not reflect all the major developments in safety and health practices that have already been accepted by the emergency response community and incorporated into industry consensus standards. The regulatory effort began in 2007 with a Request for Information (RFI). In July 2014, OSHA hosted two stakeholder meetings with participants representing a broad range of emergency responders as well as allied stakeholders such as State Plan representatives, skilled support workers, and law enforcement. Given the broad support and interest seen during the stakeholder meetings, OSHA decided to move forward with a comprehensive proposed standard for emergency response. In September 2015, OSHA requested, and NACOSH designated, a subcommittee made up of major stakeholders and charged with developing proposed regulatory text. In October 2021, a Small Business Advocacy Review (SBAR) panel was assembled, as required by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA); SBREFA was concluded in December 2021. OSHA published a Notice of Proposed Rulemaking (NPRM) in February 2024. To encourage and increase stakeholder feedback regarding the proposed rule, OSHA twice extended the original 90-day public comment period. The agency also held informal public hearings. OSHA is currently making revisions based on the analysis of the testimony and evidence provided during this public hearing and post-hearing comment period.

Status: Publication of a Final Rule is targeted for April 2027. Based on the Trump Unified Regulatory Agenda for 2026, it appears that agencies like EPA and OSHA will continue to consider
deregulatory actions. IIAR is actively monitoring these developments and engaging with agency officials to advance the interests of the natural refrigerants industry.