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Letters & Comments

Read »Æ¶¹¶Ì¾ç’s letters and comments submitted to regulatory bodies and elected officials.
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»Æ¶¹¶Ì¾ç, Coalition Seek Meeting with EPA Administrator to Discuss Amendments RMP Rule

»Æ¶¹¶Ì¾ç and 15 other organizations sent a letter to new EPA Administrator Lee Zeldin requesting a meeting to discuss the recent amendments to the Risk Management Program (RMP) rule. Some RMP rule requirement are already in effect while others go into effect in May 2027. Since 2017, the RMP requirements have been in flux based on the changing presidential administrations. The coalition seeks to work with U.S. EPA to develop a lasting process that will address safety concerns with the final RMP Rule amendments.

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»Æ¶¹¶Ì¾ç Comments to Green Seal on PFAS in GS-11 Standard for Paints, Coatings, Stains and Sealers

»Æ¶¹¶Ì¾ç submitted comments to Green Seal on the organization's proposed changes to GS-11 related to per- and polyfluoroalkyl substances (PFAS) in paints, coatings, stains and sealers. In its comments, »Æ¶¹¶Ì¾ç noted that the proposed changes to GS-11 do not accurately reflect the marketplace for PFAS in coatings, nor are they indicative of environmental or human health impact of coatings with fluorinated chemistries.

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»Æ¶¹¶Ì¾ç Submits Comments on LEED v5, Second Round

»Æ¶¹¶Ì¾ç submitted a second round of comments to U.S. Green Building Council (USGBC) on the Leadership in Energy and Environmental Design (LEED) v5. The LEED system is the most widely-recognized and widely-used green building system in the world. Earlier in 2024, USGBC released the first draft version of the LEED v5 rating systems for public comment.

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»Æ¶¹¶Ì¾ç Comments on Maine's draft PFAS bill and Report to Legislature

»Æ¶¹¶Ì¾ç submitted comments to Vermont’s Department of Environmental Conservation (DEC), which is developing a draft PFAS bill and a report to the legislature. Maine's Act 131, Phase Out of PFAS Added Products, would establish a general prohibition of PFAS added products that will take effect six (6) months after one of the other Northeast states adopts similar legislation, affecting at least 10,000,000 people. »Æ¶¹¶Ì¾ç underscored the need for the definition of PFAS to be aligned with EPA’s definition under its TSCA Section 8(a)(7) reporting rule, with a structural definition based on compounds with two or more fluorinated carbon atoms.

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»Æ¶¹¶Ì¾ç, Coalition Support NO IRIS Act of 2024

»Æ¶¹¶Ì¾ç joined a coalition letter of support to Congressional sponsors of the “No Industrial Restrictions In Secret (NO IRIS) Act of 2024â€� (S. 3724/H.R. 7284). Increasingly, the Environmental Protection Agency’s Integrated Risk Information System program (IRIS) is being used to justify overly burdensome regulations on critical chemistries essential for everyday products. The NO IRIS Act would protect American manufacturing and ensure regulations are based on sound science.

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