ACA Comments on Maine's Second Concept Draft for PFAS
On Nov. 10, ACA submitted detailed comments to the Maine Department of Environmental Protection (DEP) on the Second Concept Draft for regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Pollution. ACA continues to engage with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment.
ACA Joins Coaltion Comments to EPA on Proposed RMP Amendments
ACA was among 20 organizations that submitted joint comments to the U.S. EPA on the agency's Risk Management Program (RMP) proposed amendments. The detailed comments included several recommendations and other input for EPA consideration.
ACA Comments on EPA's Proposed RMP Amendments
ACA's Oct. 31 comments to EPA noted that many of the agency's proposed amendments to the RMP rule aim to improve upon prevention program elements of particular types of facilities, promote information availability, and emergency response measures, and that ACA shares EPA’s goal of ensuring people both inside and outside of chemical facilities are safe and prevent any catastrophic chemical accidents. However, some of EPA’s proposed changes (as currently drafted) will not serve to improve the safety within a chemical facility, but rather create significant burdens on a facility that would result in higher costs to the facility with no corresponding improvement in safety.
ACA Letter Urges President to Work with Railroads and Unions to Ratify Tentative Agreement
ACA joined more than 300 trade associations in a letter to President Biden urging continued "work with the railroad unions and railroads to ensure that the tentative agreement that you helped broker is ratified by the parties. It is paramount that these contracts now be ratified, as a rail shutdown would have a significant impact on the U.S. economy and lead to further inflationary pressure."
ACA Comments on MI EGLE VOC RACT Rule
On Oct. 26, ACA submitted comments to the Michigan Department of Environment, Great Lakes, and Energy (MI EGLE) on the department's proposed VOC RACT Rule. Among its comments, ACA asked the agency to dopt a compliance date of one year from the date of adoption of a final rule for the various coatings rules included in the proposed VOC RACT Rule (Part 6).
ACA Comments on PHMSA Information on Electronic Hazard Communication Alternatives RFI
On Oct. 24, ACA responded to the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding its request for information on electronic hazard communication alternatives. In its comments, ACA expressed support for an electronic alternative would provide for a more efficient and effective means to exchange information between shippers and transporters, especially in multi-modal operations.
World Coatings Council Supports WHO International Lead Poisoning Prevention Week of Action
The World Coatings Council (WCC) supports the World Health Organization’s (WHO) International Lead Poisoning Prevention Week of Action, Oct. 23-29, 2022. During the campaign week, the Global Alliance to Eliminate Lead Paint (also known as the Lead Paint Alliance or LPA) reminds governments, civil society organizations, health partners, industry, and others of the unacceptable risks of lead exposure and the need for action. The campaign builds on the success in outlawing the use of lead in petrol and the progress achieved by many countries in establishing laws that limit the use of lead in paint, particularly those paints to which children are exposed in their homes, schools, and playgrounds. WCC applauds the WHO’s “say no to lead poisoning” campaign.
ACA, Others Seek RMP Proposed Rule Comment Extension
On Oct. 4, ACA along with several other organizations asked U.S. EPA to provide a minimum 60-day extension of the comment period on EPA’s
“Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention” proposed rule. "Given the complex nature of the policy, economic, and technical issues raised in the notice and interaction with other agency regulations, an extension would assist our organizations and other commenters in providing thoughtful, considered comments on the notice."
ACA, Coalition Seek Comment Extension on EPA Proposal for PFOA/PFOS under CERCLA
On Sept. 13, ACA and a collation of other organizations submitted a letter to U.S. EPA requesting an additional 60-day extension of the deadline for public comment on EPA’s proposed rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The same extension was requested with respect to the accompanying Economic Assessment of the Potential Costs and Other Impacts of the proposed rulemaking.
ACA Comments to MPCA Seek Continuance of PaintCare Architectural Paint Stewardship Assessment
ACA submited comments to the Minnesota Pollution Control Agency (MPCA) on PaintCare’s request for a continuance of the Minnesota Architectural Paint Stewardship Assessment at the current levels. In its comments, ACA notes that while MPCA should and must evaluate PaintCare’s program to ensure that it is fulfilling its statutory obligations, business decisions regarding the program’s day to day operations as well as other business functions should be left to those working in the program. "Determining an appropriate reserves policy is such a business decision."