ACA, Coalition Comments on Proposed Changes to TSCA PFAS Reporting
ACA joined a coalition of organizations that submitted comments to U.S. EPA on the proposed revisions to the Toxic Substances Control Act (TSCA) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). These changes seek to reduce regulatory burdens on businesses and according to EPA estimates, will significantly reduce the economic impact on businesses with cost savings of $786 to $843 million.
ACA Submits Comments to EPA on Proposed PFAS Reporting
ACA submitted detailed comments to U.S. EPA on the agency's proposed revisions to the Toxic Substances Control Act (TSCA) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). In its comments, ACA underscored the substantive compliance costs for industry and urged EPA to revisits its cost estimates, and also recommended other changes to the rule, including modifying the due diligence standard; establishing an additional volume-based threshold; clarifying scope of the exemption for articles with coatings; and restricting the scope of reportable PFAS, among other suggestions.
ACA Letter to California Law Revision Commission
ACA joined a multi-association letter California Law Revision Commission raising concerns with potential efforts by California to establish a legal standard for merger review that impedes, contradicts, or otherwise departs from the standard set by federal law. ACA believes such a move would risk disrupting national commerce, creating unnecessary regulatory burdens, and undermining the efficiency and predictability that businesses rely upon to operate and grow.
ACA Comments to CDPHE on Proposed Regs for Solid Waste Sites
ACA submitted comments to the Colorado Department of Public Health and Environment on revised Proposed Amendments to Section 18 of the Regulations for Solid Waste Sites and Facilities. In its comments, ACA urged that the proposed definition of ‘small business’ be revised. ACA also pressed for the revised proposed amendments to provide that producers may request a hearing to contest any assessed dues.
ACA Outreach to EPA on Chemical Risk Evaluation under TSCA
In comments ACA submitted to U.S. EPA's Nancy Beck, Principal Deputy Assistant Administrator for the agency's Office of Chemical Safety and Pollution Prevention, ACA addressed proposed revisions to procedures for chemical risk evaluation under TSCA. ACA supports removal of codification of the “whole chemical approach,” and also stressed the importance of making case-by-case determinations regarding scope of risk evaluations.
ACA Supports USMCA in Feedback to U.S. Trade Representative
In a letter to the U.S. Trade Representative (USTR), ACA expressed strong support for the United States–Mexico–Canada Agreement (USMCA) as it approaches a Joint Review, required under Article 34.7 of the agreement. Canada and Mexico are the U.S. coatings industry's two largest trading partners. The U.S. paint and coatings industry has enjoyed the benefits of a well-developed trade infrastructure, including tariff-free markets as well as new digital trade provisions, a streamlined import-document submission procedure and higher de minimis shipment values. ACA notes that these and other benefits of the USMCA have helped to ease some of the regulatory burdens associated with an integrated North American supply and manufacturing chain. ACA urged the USTR to focus on continued implementation of the USMCA, rather than a broad renegotiation of its elements, noting that preservation of the USMCA's key tax and tariff provisions are paramount in the Joint Review effort.
Letter to Senate EPW Subcommittee on Chemical Safety, Waste Management, Environmental Justice and Regulatory Oversight
ACA sent a letter to the leadership of the U.S. Senate Committee on Environment and Public Works' Subcommittee on Chemical Safety, Waste Management, Environmental Justice and Regulatory Oversight. The letter, sent in advance of the Subcommittee's hearing on on the "Beneficial Use and Regulation of Chemicals," underscored several challenges arising from implementation of the Lautenberg amendments to TSCA that continue to plague EPA and bottleneck the chemical review process, which in turn, has created significant obstacles to innovation and competitiveness in the paint and coatings industry.
ACA Raises Concern about Staff Reductions at UNECE Transport Division
In a letter to the U.S. Mission to the United Nations and Other International Organizations in Geneva, ACA expressed concerns about proposed staff reductions at the UN Economic Commission for Europe (UNECE), Transport Division, and specifically the Dangerous Goods Section. ACA underscored the critical work overseen by the commission ensures uninterrupted multi-modal transport of goods that are essential to our daily lives, supports national and multi-national security need, and establishes a harmonized transport safety baseline supporting fair economic competitive opportunities.
ACA Comments to CalRecycle on Proposed Regs for SB54
In its comments submitted to the California Department of Resources Recycling and Recovery (CalRecycle) on the agency’s proposed permanent regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), ACA made several recommendations to alleviate any undue burden imposed on the paint and coatings industry. Chief among those, ACA urged the agency to revise the proposed definitions for the terms ‘plastic’ and ‘plastic or polymers.’
ACA Supports Nomination of Douglas Troutman for Role at U.S. EPA
ACA joined a number of industry associations in supporting the nomination of Douglas M. Troutman as Assistant Administrator for U.S. EPA's Office of Chemical Safety and Pollution Prevention (OCSPP). In a letter submitted to the Senate Environment and Public Works Committee ahead of his confirmation hearing, ACA and the coalition of trade association noted that Troutman has been an effective advocate for risk-based policies based on the best available science, and a collaborative partner with decades of experience working with stakeholders and policymakers.