ƶ̾ Comments on Maine’s Reposted Draft Rule for Packaging Stewardship Program
ƶ̾ submitted comments to Maine's Department of Environmental Protection on the agency's reposted draft rule: Stewardship Program for Packaging. The department made changes to the draft rules based on the comments received in late 2023 and early 2024 and reposted them to allow for additional public comment. These draft rules provide details for implementing the Stewardship Program for Packaging that aims to reduce the burden on municipalities for managing packaging material.
ƶ̾ Comments on Oregon’s Proposed Rulemaking: Plastic Pollution and Recycling Modernization Act
ƶ̾ submitted comments to Oregon Department of Environmental Quality regarding the proposed rulemaking for the Plastic Pollution and Recycling Modernization Act. The Act requires producers of packaging, paper products, and food serviceware to support and expand recycling services in Oregon for their products.
ƶ̾ Urges Senate Leadership to Include CFATS Reauthorization in NDAA
ƶ̾ joined several organizations in a letter to Senate leaders urging the inclusion of language from the Carper-Peters amendment in the National Defense Authorization Act (NDAA) for Fiscal Year 2024 (S. 4638), which reauthorizes the Chemical Facility Anti-Terrorism Standards (CFATS through October 1, 2026, into the substitute NDAA bill that will be filed soon.
ƶ̾ Comments on OSHA’s Proposed Emergency Response Standard
ƶ̾'s comments focused on Workplace Emergency Response Employers, and generally expressed concern that the covered emergency activities are unnecessarily broad, adressing relatively minor emergency responses.
ƶ̾, Coalition Oppose Extension for Detention and Demurrage Billing Requirements Final Rule
ƶ̾ joined more than 60 organizations expressing strong opposition to the petition filed by the Ocean Carrier Equipment Management Association to extend the effective date of the Detention and Demurrage Billing Requirements Final Rule. The coalition letter urged the Federal Maritime Commission to reject the petition.
ƶ̾ Supports California SB 1143, PaintCare Expansion
The bill makes technical but important changes to California’s PaintCare architectural paint recovery program. Specifically, the proposed changes incorporate non-industrial coatings and coatings-related products as product categories that can be managed under the scope of California’s existing PaintCare program.
ƶ̾, Coalition Urge Support for the Regulatory Early Notice and Engagement Act
ƶ̾ joined a coalition letter to members of Congress urging sponsorship and support for H.R. 8204, the Regulatory Early Notice and Engagement Act. This bipartisan legislation would reform the federal regulatory process to make it more transparent, accountable, and responsive to the public.
ƶ̾ Comments to Nevada's Clark County Department of Environment & Sustainability on Proposed AIM Coatings Rule
In its comments ƶ̾ urged a compliance date of at least one year from the date of final rule adoption, as well as sell-through provision for three years after the effective date of the final rule.
ƶ̾ Responds to EPA’s Request on Unpublished Health and Safety Studies
EPA is proposing to add 16 chemical substances to lists at 40 CFR 716.120, triggering a reporting requirement within 90 days of finalizing the rule. Chemical substances include those undergoing prioritization and chemicals that EPA may select for future prioritization. Manufacturers and importers would be required to submit health and safety studies “known to” them or lists of studies where appropriate, including studies describing physical characteristics, environmental degradation, general population monitoring, etc.
ƶ̾, Coalition ask FTC to Stay and Delay Implementation of the Noncompete Rule
ƶ̾ joined a coalition letter sent to the U.S. Federal Trade Commissioners requesting that the FTC stay the effective date of the Non-Compete Clause Final Rule (89 Fed. Reg. 38,342-38,506, “Noncompete Rule”) to allow for judicial review.