ACA Letter Urges President to Work with Railroads and Unions to Ratify Tentative Agreement
ACA joined more than 300 trade associations in a letter to President Biden urging continued "work with the railroad unions and railroads to ensure that the tentative agreement that you helped broker is ratified by the parties. It is paramount that these contracts now be ratified, as a rail shutdown would have a significant impact on the U.S. economy and lead to further inflationary pressure."
ACA Comments on MI EGLE VOC RACT Rule
On Oct. 26, ACA submitted comments to the Michigan Department of Environment, Great Lakes, and Energy (MI EGLE) on the department's proposed VOC RACT Rule. Among its comments, ACA asked the agency to dopt a compliance date of one year from the date of adoption of a final rule for the various coatings rules included in the proposed VOC RACT Rule (Part 6).
ACA Comments on PHMSA Information on Electronic Hazard Communication Alternatives RFI
On Oct. 24, ACA responded to the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding its request for information on electronic hazard communication alternatives. In its comments, ACA expressed support for an electronic alternative would provide for a more efficient and effective means to exchange information between shippers and transporters, especially in multi-modal operations.
World Coatings Council Supports WHO International Lead Poisoning Prevention Week of Action
The World Coatings Council (WCC) supports the World Health Organization’s (WHO) International Lead Poisoning Prevention Week of Action, Oct. 23-29, 2022. During the campaign week, the Global Alliance to Eliminate Lead Paint (also known as the Lead Paint Alliance or LPA) reminds governments, civil society organizations, health partners, industry, and others of the unacceptable risks of lead exposure and the need for action. The campaign builds on the success in outlawing the use of lead in petrol and the progress achieved by many countries in establishing laws that limit the use of lead in paint, particularly those paints to which children are exposed in their homes, schools, and playgrounds. WCC applauds the WHO’s “say no to lead poisoning” campaign.
ACA, Others Seek RMP Proposed Rule Comment Extension
On Oct. 4, ACA along with several other organizations asked U.S. EPA to provide a minimum 60-day extension of the comment period on EPA’s
“Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention” proposed rule. "Given the complex nature of the policy, economic, and technical issues raised in the notice and interaction with other agency regulations, an extension would assist our organizations and other commenters in providing thoughtful, considered comments on the notice."
ACA, Coalition Seek Comment Extension on EPA Proposal for PFOA/PFOS under CERCLA
On Sept. 13, ACA and a collation of other organizations submitted a letter to U.S. EPA requesting an additional 60-day extension of the deadline for public comment on EPA’s proposed rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The same extension was requested with respect to the accompanying Economic Assessment of the Potential Costs and Other Impacts of the proposed rulemaking.
ACA Comments to MPCA Seek Continuance of PaintCare Architectural Paint Stewardship Assessment
ACA submited comments to the Minnesota Pollution Control Agency (MPCA) on PaintCare’s request for a continuance of the Minnesota Architectural Paint Stewardship Assessment at the current levels. In its comments, ACA notes that while MPCA should and must evaluate PaintCare’s program to ensure that it is fulfilling its statutory obligations, business decisions regarding the program’s day to day operations as well as other business functions should be left to those working in the program. "Determining an appropriate reserves policy is such a business decision."
ACA, Coalition Urge "No" Vote on California SB 260
ACA joined the California Chamber of Commerce and several other organizations urging state legislators to vote "no" on California Senate Bill 260. SB 260 requires the California Air Resources Board (CARB) to adopt regulations requiring the reporting of greenhouse gas emission data throughout the entire supply chain to include activities such as business travel, employee commutes, procurement, waste, and water usage, regardless of location. These types of emissions, also known as “Scope 3” emissions, are the result of activities from assets not owned or controlled by the reporting entity and encompass activities both upstream and downstream of a company’s main operations.
ACA Letter on Passage of CHIPS Act
ACA's letter to Congressional leadership lauded bipartisan efforts to pass the CHIPS and Science Act to strengthen the ability of American workers and companies to compete globally, including with China. The letter also expressed disappointment that Congress dropped the Trade Title from earlier versions of this legislation (USICA/COMPETES Act), which included the expired Miscellaneous Tariff Bill (MTB). The MTB would temporarily eliminate and reduce border taxes on a set of products that are not produced at all domestically or in sufficient capacity in the United States as confirmed by a rigorous and transparent process. "Without passage of the MTB, American consumers will pay directly and/or indirectly hundreds of millions of dollars each year in government-imposed import taxes on products not made or available in the United States."
ACA Comments on EPA's Proposed Amendments to NESHAP for Miscellaneous Coatings Manufacturing Facilities
In its Aug. 8 comments to U.S. EPA, ACA asked the agency to make additional changes to its proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coatings Manufacturing (MCM) facilities.