Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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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.

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ACA Supports Clarification of Build America, Buy America Requirements

In its letter to the U.S. House Committee on Transportation and Infrastructure Subcommittee on Highways and Transit, ACA expressed support for efforts to better understand the current  administration’s implementation of Build America, Buy America, including those provisions that were in the Infrastructure Investment and Jobs Act.

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ACA Urges Immediate CFATS Reauthorization

ACA and a coalition of other organizations urged Congressional leadership to reauthorize the critical Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS) program that expired July 28, 2023. The CFATS program's primary mission is to help reduce the risk of a terrorist attack on the highest-risk chemical facilities by addressing a wide range of potential threats by bad actors.

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ACA & PaintCare Submit Universal Waste Petition to EPA

In this petition to U.S. EPA, ACA and PaintCare request that that paint wastes be designated “universal waste” under 40 CFR Section 273. This rulemaking petition formally requests EPA to consider adding paint wastes to the federal universal waste rule. Although paint wastes are not currently on the federal universal waste rule, several states have implemented state-level universal waste rules to include paint wastes. Including paint wastes under the federal universal waste rule would not only ease the regulatory burden experienced by paint manufacturers, paint retailers, paint haulers, and paint recyclers by streamlining management standards, but also promote diverting these wastes from solid landfills.

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ACA Comments to Washington DOE on Draft Report for Antifouling Paints

ACA has submitted comments to the Washington State Department of Ecology (DOE) draft report to the state legislature regarding antifouling paints. Notably, DOE's draft report highlights the importance of ensuring that there are safe and efficacious antifouling paint products for sale and use in Washington state.

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ACA Supports Proposal to Align Ohio Rule of Evidence 702 Updated Federal Counterpart

The proposed amendment to Ohio Rule 702 clarifies that the proponent of expert testimony must demonstrate “to the court that it is more likely than not” that the rule’s existing admissibility requirements are met. The amendment underscores the need for judges to act as “gatekeepers” against the admission of unreliable expert testimony. ACA supports this amendment because clarifying the Ohio rule will help avoid misapplication of the rule that has occurred with the analog federal rule and will promote harmony in Ohio’s state and federal courts.

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ACA Comments on Prop 65 Short-Form Proposal

ACA submitted comments to the California Office of Environmental Health Hazard Assessment on the proposed amendments to short-form warnings under Article 6 of regulations implementing the California Safe Drinking Water and Toxic Enforcement Act — Proposition 65.

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