ACA Comments to Nevada's Clark County Department of Environment & Sustainability on Proposed AIM Coatings Rule
In its comments ACA urged a compliance date of at least one year from the date of final rule adoption, as well as sell-through provision for three years after the effective date of the final rule.
ACA Responds to EPA’s Request on Unpublished Health and Safety Studies
EPA is proposing to add 16 chemical substances to lists at 40 CFR 716.120, triggering a reporting requirement within 90 days of finalizing the rule. Chemical substances include those undergoing prioritization and chemicals that EPA may select for future prioritization. Manufacturers and importers would be required to submit health and safety studies “known to” them or lists of studies where appropriate, including studies describing physical characteristics, environmental degradation, general population monitoring, etc.
ACA, Coalition ask FTC to Stay and Delay Implementation of the Noncompete Rule
ACA joined a coalition letter sent to the U.S. Federal Trade Commissioners requesting that the FTC stay the effective date of the Non-Compete Clause Final Rule (89 Fed. Reg. 38,342-38,506, “Noncompete Rule”) to allow for judicial review.
ACA Submits Comments to USGBC on LEED v5
This letter consolidates ACA’s comments to U.S. Green Building Council (USGBC) on LEED v5, which is the newest version of LEED. LEED (Leadership in Energy and Environmental Design) is the world's most widely used green building rating system and is globally recognized as such.
ACA, Coalition Urge Exclusion of Certain PFAS Provisions from FY 25 NDAA
ACA joined a coalition letter to Congressional leaders on the Armed Services Committees urging them not to include provisions in the National Defense Authorization Act for Fiscal Year 2025 (FY 25 NDAA) that would circumvent the existing legal and regulatory processes for per- and polyfluoroalkyl substances (PFAS).
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.