ƶ̾ Comments on PFAS TRI Reporting
On Feb. 3, ƶ̾ submitted comments to U.S. EPA on proposed changes to PFAS reporting in the Toxics Release Inventory (TRI) and supplier notification requirements. ƶ̾ 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
ƶ̾ submitted written comments to the Washington State Legislature at it considers a measure to reassess standards for polychlorinated biphenyls in consumer products. “ƶ̾ 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.”
ƶ̾ Joint Letter on SEC Proposed Climate Reporting Rule
ƶ̾ 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.
ƶ̾ Comments on New York’s Proposed Hazardous Waste Revisions to the Universal Waste Rule
On Jan. 17, ƶ̾ submitted comments to the New York State Department of Conservation on the agency's proposed hazardous waste management regulatory revisions. ƶ̾ has a significant interest in assisting our industry in pollution prevention strategies and compliance with RCRA requirements.
ƶ̾ Comments to EPA onTSCA Administration Fee Proposal
On Jan. 17, ƶ̾ submitted comments to U.S. EPA on the agency's proposed changes to fees to administer the Toxic Substances Control Act (TSCA). ƶ̾'s comments made a number of suggestions for EPA consideration.
ƶ̾ Comments on EPA’s PFAS Reporting Rule IRFA
ƶ̾ 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).
Comments on PHMSA's Hazardous Materials Registration and Fee Assessment Program
ƶ̾ joined the Interested Parties for Hazardous Materials Transportation in a letter to the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration on potential adjustments to the agency’s hazardous materials registration and fee assessment program.
ƶ̾, Others Urge EPA to Extend PFAS Reporting Rule Comment Deadline
ƶ̾ joined 17 other organizations in a letter to U.S. EPA requesting that the agency extend the comment period for the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule by 30 days.
Letter to Congressional Leadership for Action to Avert a Rail Strike
On Nov. 28, ƶ̾ joined more than 400 organizations in a letter to Congressional leadership urging action to avert a rail strike. “While a voluntary agreement with the four holdout unions is the best outcome, the risks to America’s economy and communities simply make a national rail strike unacceptable,” the letter stated. “Therefore, absent a voluntary agreement, we call on you to take immediate steps to prevent a national rail strike and the certain economic destruction that would follow.”
ƶ̾ Comments on Maine's Second Concept Draft for PFAS
On Nov. 10, ƶ̾ 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. ƶ̾ 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.