ƶ̾ Letter on Passage of CHIPS Act
ƶ̾'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."
ƶ̾ Comments on EPA's Proposed Amendments to NESHAP for Miscellaneous Coatings Manufacturing Facilities
In its Aug. 8 comments to U.S. EPA, ƶ̾ 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.
ƶ̾ 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. ƶ̾ 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.
ƶ̾ 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. ƶ̾ 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.
ƶ̾ Comments on Maine Concept Draft for PFAS Reporting Implementing LD 1503
ƶ̾ 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."
ƶ̾ Comments via Downstream Users Coalition on EPA Proposed Risk Mitigation Rule on Asbestos (Asbestos I Risk Evaluation)
ƶ̾ 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).
ƶ̾ Comments on EPA Proposed Rule for Claiming CBI under TSCA
ƶ̾ supports and commends EPA’s initiative in developing a proposed regulations affecting assertion, EPA review, and treatment of confidentiality claims. ƶ̾’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)
ƶ̾ 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.”
ƶ̾ Comments: EPA Proposed Reporting Rule for Asbestiform Minerals
ƶ̾ 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
ƶ̾ 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.”