ACA Comments on EPA’s Proposed Risk Evaluation of Formaldehyde
In its comments ACA noted that evaluating paints and adhesives separately from processing formaldehyde into resins would provide a more accurate assessment.
ACA Comments on FHWA Proposed Rulemaking Related to BABA
ACA submitted comments to the Federal Highway Administration's (FHWA) proposed rule to discontinue the general waiver of Buy America requirements for manufactured products and require FHWA recipients to apply Buy America requirements to manufactured products. ACA urged the agency to continue to operate under the General Waiver of Buy America requirements for manufactured products as it has since 1983, and not apply BABA requirements to manufactured products at this time.
ACA Comments on California's Proposed Regulations for Plastic Pollution and Packaging Producer Responsibility Act (SB 54)
ACA submitted comments to the California Department of Resources Recycling and Recovery (CalRecycle) regarding proposed regulations for SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act.
ACA, Coalition Urge CRA Resolution on EPA's PM2.5
ACA signed onto a coalition letter urging Congressional leaders to pass a Congressional Review Act resolution to disapprove the U.S. EPA’s recently finalized rule that unnecessarily tightened the National Ambient Air Quality Standards for fine particulate matter (PM2.5), which will have an adverse impact on economic growth.
ACA Joins Letter to IRS on Superfund Chemical Taxes
ACA joined several other organizations representing American businesses subject to the excise taxes, reinstated by the Infrastructure Investment and Jobs Act, on certain chemicals and imported chemical substances under Internal Revenue Code sections 4661 through 4672 beginning July 1, 2022 (the “Superfund taxes”). ACA and others asked IRS for additional clarity on the process by which eligible companies may receive a refund on paid Superfund taxes.
ACA Joins Multi-Organization Letter to EPA on CARB Locomotive Request
In the letter, the organizations raise serious concerns about an authorization request from the California Air Resources Board (CARB) pertaining to rail locomotive emissions. This regulation from CARB has the potential to create significant disruptions in the supply chain for all sectors of the U.S. economy, especially manufacturers and shippers who rely on consistent, reliable rail service.
ACA, Coalition Comments to Congress on Recent RMP Amendments
ACA was among 14 organizations that submitted joint comments to the Congress seeking support for legislation, H.J.Res.123, that disapproves of the recent finalized amendments to the Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (“RMP rule”).
ACA Comments on Colorado's Proposed Producer Responsibility Regulations
ACA submitted comments to the Colorado Department of Public Health and Environment with recommendations on the agency's proposed Producer Responsibility Regulations for plastic packaging under the Solid Waste and Materials Management Program.
ACA, Coalition Submit Comments to EPA on Proposed RCRA Hazardous Constituent Listing of Nine PFAS
ACA was part of the U.S. Chamber of Commerce’s Coalition of Companies, trade associations, and other stakeholders on the U.S. Environmental Protection Agency’s Proposed Rule, Listing of Specific PFAS as Hazardous Constituents.
ACA Comments on EPA’s Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials
ACA submitted comments to the U.S. Environmental Protection Agency (EPA) on its Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials. EPA is developing a program to identify and label construction materials and products that have substantially lower embodied carbon as part of the Inflation Reduction Act. This is in coordination with General Services Administration and Department of Transportation Federal Highway Administration.