»Æ¶¹¶Ì¾ç Joins Coalition Comments on EPA’s RMP Proposal
»Æ¶¹¶Ì¾ç joined a coalition of organizations in comments submitted to the U.S. Environmental Protection Agency (EPA) on its proposal related to the Risk Management Programs (RMP). The comments, which address the agency’s accidental release prevention requirements under the RMP, underscore that any final rule stemming from EPA’s proposal should be fully consistent with statutory authority; supported by the administrative record; and structured to preserve the effectiveness of the performance-based RMP framework.
»Æ¶¹¶Ì¾ç Comments on New York Senate Bill 1464A
»Æ¶¹¶Ì¾ç submitted comments to the New York Senate's Environmental Conservation Committee on Senate Bill 1464A, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. In its comments, »Æ¶¹¶Ì¾ç urged the committee to amend the definition of ‘packaging material,’ ‘packaging,’ or ‘covered material,’ to clarify that packaging for products subject to a post-consumer paint program under N.Y. Env’t Conserv. Law § 27-20 are not included under S1464A.
»Æ¶¹¶Ì¾ç, AAI Coalition Support Congressional Efforts for TSCA Improvements
»Æ¶¹¶Ì¾ç joined the American Alliance for Innovation (AAI) letter to members of Congress expressing support for efforts to improve the Toxic Substances Control Act (TSCA). The letter signed by more than 100 organizations lauded Congressional committee work to enhance TSCA to ensure a chemical regulatory program at U.S. EPA is properly resourced, does not impede or create unnecessary barriers to technological innovation while avoiding unreasonable risks of injury, and supports growth in the manufacturing sector.
»Æ¶¹¶Ì¾ç Comments on Maryland's Proposed Packaging Regulations
»Æ¶¹¶Ì¾ç submitted comments to the Maryland Department of Environment (MDE) on the agency's proposed Producer Responsibility Packaging and Paper Products Regulations. »Æ¶¹¶Ì¾ç urged MDE to define ‘de minimis producer’ as an individual that, in the most recent fiscal year, has generated less than a total gross revenue of $5,000,000. »Æ¶¹¶Ì¾ç also sought clear exemptions under the regulations for all primary, secondary, and tertiary packaging associated with products subject to Maryland’s paint stewardship program.
»Æ¶¹¶Ì¾ç Supports USMCA Extension in Letter to Senate Leaders
In a letter to leaders of the U.S. Senate Committee on Finance, »Æ¶¹¶Ì¾ç expressed strong support for the U.S.-Mexico-Canada Agreement (USMCA), as Canada and Mexico are the two largest trading partners for the U.S. coatings industry. »Æ¶¹¶Ì¾ç urged extension of the agreement for 10 to 16 years and that the United States focus on continued implementation of the USMCA during the Joint Review effort rather than a broad renegotiation of its elements, underscoring that preservation of the USMCA's key tax and tariff provisions are paramount.
»Æ¶¹¶Ì¾ç Comments on CARB's Proposed Regs for Climate Disclosure
»Æ¶¹¶Ì¾ç submitted comments to California's Air Resources Board on the agency’s Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation for the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). »Æ¶¹¶Ì¾ç underscored in its comments that businesses in the paint and coatings industry should be exempt from the reporting requirements of SB 253 and SB 261, since they are already subject to a plethora of reporting requirements in air quality and toxics regulations in the state.
»Æ¶¹¶Ì¾ç Submits Comments to California DTSC on Possible Consumer Product Listing for Microplastics
»Æ¶¹¶Ì¾ç submitted detailed comments to California’s Department of Toxic Substances Control (DTSC) on the agency’s background document identifying consumer products for possible listing as priority products for microplastic pollution under the state’s Safer Consumer Products Program. »Æ¶¹¶Ì¾ç vigorously opposed the potential listing of water-based interior wall-paint cited in the background document, underscoring that paint particles are not microplastics and studies do not establish a clear correlation between paint and microplastic pollution.
»Æ¶¹¶Ì¾ç Comments on Washington HB 2271
»Æ¶¹¶Ì¾ç submitted comments to Washington state’s House Environment & Energy Committee on proposed House Bill 2271, An Act Relating to Postconsumer Recycled Content Requirements for Plastic Products. »Æ¶¹¶Ì¾ç urged that the bill’s language be amended to clarify that packaging for products subject to the state’s PaintCare program are considered exempted PCRC 2.0 products.
»Æ¶¹¶Ì¾ç, Coalition Comments on Proposed Changes to TSCA PFAS Reporting
»Æ¶¹¶Ì¾ç joined a coalition of organizations that submitted comments to U.S. EPA  on the proposed revisions to the Toxic Substances Control Act (TSCA) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). These changes seek to reduce regulatory burdens on businesses and according to EPA estimates, will significantly reduce the economic impact on businesses with cost savings of $786 to $843 million.
»Æ¶¹¶Ì¾ç Submits Comments to EPA on Proposed PFAS Reporting
»Æ¶¹¶Ì¾ç submitted detailed comments to U.S. EPA on the agency's proposed revisions to the Toxic Substances Control Act (TSCA) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). In its comments, »Æ¶¹¶Ì¾ç underscored the substantive compliance costs for industry and urged EPA to revisits its cost estimates, and also recommended other changes to the rule, including modifying the due diligence standard; establishing an additional volume-based threshold; clarifying scope of the exemption for articles with coatings; and restricting the scope of reportable PFAS, among other suggestions.