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."
ACA, Coalition Urge "No" Vote on California SB 260
ACA joined the California Chamber of Commerce and several other organizations urging state legislators to vote "no" on California Senate Bill 260. SB 260 requires the California Air Resources Board (CARB) to adopt regulations requiring the reporting of greenhouse gas emission data throughout the entire supply chain to include activities such as business travel, employee commutes, procurement, waste, and water usage, regardless of location. These types of emissions, also known as “Scope 3” emissions, are the result of activities from assets not owned or controlled by the reporting entity and encompass activities both upstream and downstream of a company’s main operations.
ACA Letter on Passage of CHIPS Act
ACA's letter to Congressional leadership lauded bipartisan efforts to pass the CHIPS and Science Act to strengthen the ability of American workers and companies to compete globally, including with China. The letter also expressed disappointment that Congress dropped the Trade Title from earlier versions of this legislation (USICA/COMPETES Act), which included the expired Miscellaneous Tariff Bill (MTB). The MTB would temporarily eliminate and reduce border taxes on a set of products that are not produced at all domestically or in sufficient capacity in the United States as confirmed by a rigorous and transparent process. "Without passage of the MTB, American consumers will pay directly and/or indirectly hundreds of millions of dollars each year in government-imposed import taxes on products not made or available in the United States."
ACA Comments on EPA's Proposed Amendments to NESHAP for Miscellaneous Coatings Manufacturing Facilities
In its Aug. 8 comments to U.S. EPA, ACA asked the agency to make additional changes to its proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coatings Manufacturing (MCM) facilities.
ACA Comments on EPA's Proposed Interim Decision for Propiconazole
EPA published its Proposed Interim Decision in March 2022 as part of its registration review of propiconazole. In the PID, EPA proposes a reduction in use rate to 1.12% active ingredient in the final formulated product, based on EPA’s DRA (draft risk assessment), published on December 1, 2020. ACA had filed comment in response to the DRA, noting concerns with data sets used to assess exposure of workers formulating paint, professional painters and consumers applying paint with propiconazole added as a material preservative.
ACA Comments on EPA's Proposed Interim Decision for Diuron
EPA published its Proposed Interim Registration Review Decision for Diuron in March 2022, adopting and referencing EPA’s Response to Comment on the Draft Risk Assessment for Diuron, having published the underlying Draft Risk Assessment (DRA) for Diuron in December 2020. ACA had provided comment on the DRA, noting deficiencies in data used to assess consumer and professional painter exposures during spray application of paint and worker exposure from open pouring of biocides during paint formulation.
ACA Comments on Maine Concept Draft for PFAS Reporting Implementing LD 1503
ACA submitted comments to the Maine Department of Environmental Protection (DEP) on the Concept Draft regarding regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances Pollution, 38 M.R.S. §1614. "We are committed to working with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment."
ACA Comments via Downstream Users Coalition on EPA Proposed Risk Mitigation Rule on Asbestos (Asbestos I Risk Evaluation)
ACA joined the Alliance for Automotive Innovation, Forest & Paper Association, Motor & Equipment Manufacturers Association, National Automobile Dealers Association, Toy Association, and the U.S. Tire Manufacturers Association to provide comments on the U.S. EPA's first risk management proposal issued after the passage of the Lautenberg Chemical Safety Act (LCSA).