ƶ̾, Coalition Submit Comments to EPA on Proposed RCRA Hazardous Constituent Listing of Nine PFAS
ƶ̾ was part of the U.S. Chamber of Commerce’s Coalition of Companies, trade associations, and other stakeholders on the U.S. Environmental Protection Agency’s Proposed Rule, Listing of Specific PFAS as Hazardous Constituents.
ƶ̾ Comments on EPA’s Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials
ƶ̾ 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.
ƶ̾ 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, ƶ̾ 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.
ƶ̾ Urges Immediate CFATS Reauthorization
ƶ̾ 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.
ƶ̾ & PaintCare Submit Universal Waste Petition to EPA
In this petition to U.S. EPA, ƶ̾ 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.
ƶ̾ Supports the Tax Relief for American Families and Workers Act
The Tax Relief for American Families and Workers Act will restore three tax policies vital to workers and America’s future: immediate expensing of domestic R&D expenses, enhanced interest deductibility, and 100% accelerated depreciation.
ƶ̾ Comments to Washington DOE on Draft Report for Antifouling Paints
ƶ̾ 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.
ƶ̾ 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. ƶ̾ 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.
ƶ̾ Comments on Prop 65 Short-Form Proposal
ƶ̾ 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.
ƶ̾ Comments on Vermont’s Household Hazardous Waste EPR Guidance Documents
ƶ̾ submitted comments to the Vermont Department of Environmental Conservation on the state's guidance documents relating to its Extended Producer Responsibility (EPR) law for household hazardous waste. ƶ̾'s comments sought clarification on the department's guidance germane to covered products, FAQs, and more.