ACA Comments on EPA Proposed Rule for Claiming CBI under TSCA
ACA supports and commends EPA’s initiative in developing a proposed regulations affecting assertion, EPA review, and treatment of confidentiality claims. ACA’s concerns relate to providing claimants with an adequate opportunity go engage with the agency to provide supplemental information and corrections.
Extension Request to Maine for PFAS Reporting Deadline 38 MRSA Section (3)
ACA was among several organizations that signed onto a letter requesting an extension of the deadline for reporting of products containing intentionally added substances defined as PFAS in the State of Maine that is scheduled to go into effect on January 1, 2023. “ We respectfully request the extension of the reporting deadline for the following reasons: The delay in rulemaking makes it difficult for manufacturers and companies to come into compliance, with a reporting deadline in less than six months.”
ACA Comments: EPA Proposed Reporting Rule for Asbestiform Minerals
ACA submitted comments on U.S. EPA's proposed reporting and record-keeping requirement for manufacturers, importers and processors of asbestos, including asbestos in bulk form, mixtures with asbestos or trace contaminants of asbestos and asbestos in articles, where activities occurred in the four years prior to the effective date of the rule.
EPA Proposal for Revising ‘VOC’ under CAA to Exclude Certain Hydrofluorocarbon Compounds
ACA signed onto a letter to U.S. EPA, providing comments on a specific question raised in the agency proposal to revise the regulatory definition of volatile organic compounds (VOC) under the Clean Air Act to exclude certain hydrofluorocarbon compounds. “ We believe that this rulemaking does not provide a proper vehicle for broadly examining questions about the diverse properties of PFAS chemistries, particularly regarding properties that are not related to the VOC exemption program.”
Designating PFOA and PFOS as CERCLA Hazardous Substances
ACA signed onto a multi-organization letter submitted to U.S. EPA Adminstrator Regan regarding support policy and practical solutions that will accelerate the cleanup of per-and polyfluoroalkyl substances (PFAS) in the environment. "As the U.S. Environmental Protection Agency (EPA) undertakes a rulemaking process to potentially designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), we write to express our concern over the unintended consequences this action could have on communities and companies nationwide."
Supporting Final Passage of the Ocean Shipping Reform Act
ACA signed onto a letter to Congressional leadership urging final passage of the Ocean Shipping Reform Act (S. 3580/H.R. 4996). “As U.S. companies continue to face ongoing supply chain disruptions and congestion in addition to rising inflation, it is critical for Congress to address these issues. Final passage of OSRA will help address the longstanding, systemic supply chain and port disruption issues that existed prior to the pandemic as the industry has changed significantly since the last time the Shipping Act was amended over 20 years ago.”
Excluding Select PFAS Provisions from FY 2023 NDAA
ACA signed onto a letter to Senate and House Armed Services Committee leadership urging them not to include provisions in National Defense Authorization Act for Fiscal Year 2023 (FY 23 NDAA) that would circumvent the existing regulatory process for PFAS. This includes provisions that would further restrict the procurement of PFAS-containing products and call for imposition of disposal and incineration restrictions by the Department of Defense that could prevent effective cleanups and hamper timely protection of human health.
Washington State Department of Ecology’s New Safer Products for Washington Program
ACA signed onto a multi-organization letter to express concern regarding the Washington State Department of Ecology’s new Safer Products for Washington regulatory program, authorized by legislation enacted in 2019. "While Ecology’s report, which will likely contain recommendations to prohibit specific chemistries will be finalized in June, key elements contained in the draft report issued last November, are raising serious concerns for
our respective industries and will have unintended consequences for the long-term safety and availability of products in Washington State."
House Support for America COMPETES Act and the USICA
As Congress begins the conference process to reconcile the differences between the America COMPETES Act and the U.S. Innovation and Competition Act (USICA), ACA requests House of Representatives’ support of the following: a robust Miscellaneous Tariff Bill (MTB) with full retroactivity’ inclusion of the full $52 billion for CHIPS for America Act; and funding to improve our nation’s supply chains.
Senate Support for America COMPETES Act and the USICA
As Congress begins the conference process to reconcile the differences between the America COMPETES Act and the U.S. Innovation and Competition Act (USICA), ACA requests Senate support of the following: a robust Miscellaneous Tariff Bill (MTB) with full retroactivity’ inclusion of the full $52 billion for CHIPS for America Act; and funding to improve our nation’s supply chains.