ACA Comments to EPA on Clarification of Toxic Chemicals from Automatic Additions of PFAS under NDAA
In January 2025, EPA published a proposed rule to amend the definition of “toxic chemical” at 40 CFR 372.3 so that any chemical listed pursuant to EPA’s authority under the National Defense Authorization Act FY 2020 would be a toxic chemical under the regulation. As a result, companies placing such chemicals on the market, including in mixtures, would be required to notify buyers. In recent comments submitted to EPA, ACA urged the agency not include PFAS chemicals as chemicals of special concern, pending further analysis of the listing criteria in EPCRA § 313(d)(2) for each chemical.
ACA Submits Testimony on Maryland Senate Bill 90, Packaging EPR
ACA submitted testimony to the Maryland Senate Education, Energy, and the Environment Committee regarding the proposed exemptions for the term ‘packaging materials’ in Senate Bill 901, An Act concerning Environment – Packaging Materials – Producer Responsibility Plans. ACA recommended that the definition of ‘packaging materials’ in SB 901 be amended to clarify that products managed under PaintCare are not covered products.
ACA, Interested Parties Express Letter of Support for PHMSA
ACA, as part of the Interested Parties for Hazardous Materials Transportation, sent a letter to U.S Department of Transportation (DOT) Secretary Sean Duffy, expressing support of efforts to enhance the efficiency and effectiveness of government while also ensuring the continued safe and efficient transportation of hazardous materials. "In particular, we seek to highlight the critical functions of personnel who oversee the safe transport of hazardous materials within the Department of Transportation, particularly at the Pipeline and Hazardous Materials Safety Administration (PHMSA)."
Coalition Letter to House Judiciary to Support Invalidation of FTC Premerger Notification Rules
ACA joined a coalition of organizations in a letter sent to the House Judiciary Committee supporting the use of the Congressional Review Act (CRA) to overturn the Federal Trade Commission's (FTC) recent premerger notification rules. These rules have been challenged in court for violating the Administrative Procedures Act as being unnecessary and overly burdensome.
ACA, Coalition Oppose New Mexico HB 212
ACA joined a coalition letter in opposition to a New Mexico bill, HB 212, which would create a sweeping and complex new regulatory program to regulate all commercial and consumer products, as well as any industrial manufacturing processes that may use perfluoroalkyl and polyfluoroalkyl (PFAS) substances.
ACA, Coalition Seek Meeting with EPA Administrator to Discuss Amendments RMP Rule
ACA and 15 other organizations sent a letter to new EPA Administrator Lee Zeldin requesting a meeting to discuss the recent amendments to the Risk Management Program (RMP) rule. Some RMP rule requirement are already in effect while others go into effect in May 2027. Since 2017, the RMP requirements have been in flux based on the changing presidential administrations. The coalition seeks to work with U.S. EPA to develop a lasting process that will address safety concerns with the final RMP Rule amendments.
ACA Comments to EPA on Proposed Rule for Lab Use of Methylene Chloride
ACA supports modifying EPA’s methylene chloride risk mitigation rule to more accurately reflect the scope and degree of risk mitigation necessary in the laboratory environment by allowing standard laboratory ventilation in lieu of EPA’s Workplace Chemical Protection Program.
ACA Comments to Green Seal on PFAS in GS-11 Standard for Paints, Coatings, Stains and Sealers
ACA submitted comments to Green Seal on the organization's proposed changes to GS-11 related to per- and polyfluoroalkyl substances (PFAS) in paints, coatings, stains and sealers. In its comments, ACA noted that the proposed changes to GS-11 do not accurately reflect the marketplace for PFAS in coatings, nor are they indicative of environmental or human health impact of coatings with fluorinated chemistries.
ACA Joins Coalition Comments to EPA on Proposed Rule to Add Certain PFAS to TRI
ACA was one of 20 organizations that sent a letter to the U.S. Environmental Protection Agency on its proposal to add certain Per- and Polyfluoroalkyl Substances (PFAS) to the agency's Toxic Release Inventory.
ACA, Coalition Urge Continued ILA-USMX Labor Negotiations
ACA joined with more than 250 organizations sent to leaders of the International Longshoremen’s Association and the United States Maritime Alliance urging the return to the bargaining table with the goal of reaching a new labor contract before the new Jan. 15 contract expiration date.