Comments on Washington State Bills for PCBs in Consumer Products
ACA submitted written comments to the Washington State Legislature at it considers a measure to reassess standards for polychlorinated biphenyls in consumer products. “ACA supports further analysis of significant contributors to PCB contamination in Washington, but requests that paint is removed from the scope of SB 5369/HB 1314. Regulation of paint, with trace levels of inadvertent PCBs, will not significantly decrease the amount of PCB contamination in the Spokane River and other waterways in Washington or in the environment generally.”
ACA Joint Letter on SEC Proposed Climate Reporting Rule
ACA joined more than 50 other organizations in a letter to Congressional committee leaders on the SEC's proposed a new climate reporting regime that will impose substantial costs on manufacturers and interfere with their efforts to report decision-useful climate information to their investors.
ACA Comments on New York’s Proposed Hazardous Waste Revisions to the Universal Waste Rule
On Jan. 17, ACA submitted comments to the New York State Department of Conservation on the agency's proposed hazardous waste management regulatory revisions. ACA has a significant interest in assisting our industry in pollution prevention strategies and compliance with RCRA requirements.
ACA Comments to EPA onTSCA Administration Fee Proposal
On Jan. 17, ACA submitted comments to U.S. EPA on the agency's proposed changes to fees to administer the Toxic Substances Control Act (TSCA). ACA's comments made a number of suggestions for EPA consideration.
ACA Comments on EPA’s PFAS Reporting Rule IRFA
ACA submitted comments to U.S. EPA on the agency’s Initial Regulatory Flexibility Analysis and Updated Economic Analysis (IRFA) for the proposed rule, Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA).
Comments on PHMSA's Hazardous Materials Registration and Fee Assessment Program
ACA joined the Interested Parties for Hazardous Materials Transportation in a letter to the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration on potential adjustments to the agency’s hazardous materials registration and fee assessment program.
ACA, Others Urge EPA to Extend PFAS Reporting Rule Comment Deadline
ACA joined 17 other organizations in a letter to U.S. EPA requesting that the agency extend the comment period for the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule by 30 days.
Letter to Congressional Leadership for Action to Avert a Rail Strike
On Nov. 28, ACA joined more than 400 organizations in a letter to Congressional leadership urging action to avert a rail strike. “While a voluntary agreement with the four holdout unions is the best outcome, the risks to America’s economy and communities simply make a national rail strike unacceptable,” the letter stated. “Therefore, absent a voluntary agreement, we call on you to take immediate steps to prevent a national rail strike and the certain economic destruction that would follow.”
ACA Comments on Maine's Second Concept Draft for PFAS
On Nov. 10, ACA submitted detailed comments to the Maine Department of Environmental Protection (DEP) on the Second Concept Draft for regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Pollution. ACA continues to engage with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment.
ACA Joins Coaltion Comments to EPA on Proposed RMP Amendments
ACA was among 20 organizations that submitted joint comments to the U.S. EPA on the agency's Risk Management Program (RMP) proposed amendments. The detailed comments included several recommendations and other input for EPA consideration.