Opposition to Minnesota SF 834
ACA joined a coalition letter opposing Minnesota legislation, SF 834, which would impose broad reporting requirements on manufacturers of all products containing PFAS sold in Minnesota; ban the sale of products containing PFAS in a variety of product categories; and establish a future regulatory scheme to ban additional product categories containing PFAS.
Opposition Letter to Congress on FTC's Non-Compete Proposal
On Feb. 28, ACA joined a long list of organizations in a letter to Congress oppose the Federal Trade Commission’s (FTC) proposed rule to impose a nationwide ban on almost all noncompete clauses. The letter seeks Congressional oversight and close examination of the FTC’s proposed rulemaking.
ACA Comments on Washington Senate Bill 5369
On Feb. 17, ACA submitted written comments to the Washington State Senate Ways and Means Committee, in advance of a hearing on Senate Bill 5369, reassessing standards for polychlorinated biphenyls in consumer products.
ACA Urges Greater Airport Infrastructure Funding
As part of the Beyond the Runway coalition, ACA urged Congress to prioritize additional airport infrastructure funding in the upcoming FAA reauthorization bill in a recent letter to leaders of the House Committee on Transportation & Infrastructure.
ACA Comments on PFAS TRI Reporting
On Feb. 3, ACA submitted comments to U.S. EPA on proposed changes to PFAS reporting in the Toxics Release Inventory (TRI) and supplier notification requirements. ACA is concerned that listing the specified 189 PFAS chemicals as chemicals of special concern with no de minimis reporting threshold is beyond scope contemplated in EPCRA and authorization for listing in the 2020 National Defense Authorization Act.
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).