ACA, AAI Coalition Support Congressional Efforts for TSCA Improvements
鶹Ƶjoined 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.
鶹ƵComments on Maryland's Proposed Packaging Regulations
鶹Ƶsubmitted comments to the Maryland Department of Environment (MDE) on the agency's proposed Producer Responsibility Packaging and Paper Products Regulations. 鶹Ƶurged 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. 鶹Ƶalso sought clear exemptions under the regulations for all primary, secondary, and tertiary packaging associated with products subject to Maryland’s paint stewardship program.
鶹ƵSupports USMCA Extension in Letter to Senate Leaders
In a letter to leaders of the U.S. Senate Committee on Finance, 鶹Ƶexpressed 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. 鶹Ƶurged 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.
鶹ƵComments on CARB's Proposed Regs for Climate Disclosure
鶹Ƶsubmitted 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). 鶹Ƶunderscored 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.
鶹ƵSubmits Comments to California DTSC on Possible Consumer Product Listing for Microplastics
鶹Ƶsubmitted 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. 鶹Ƶvigorously 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.
鶹ƵComments on Washington HB 2271
鶹Ƶsubmitted 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. 鶹Ƶurged 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.
ACA, Coalition Comments on Proposed Changes to TSCA PFAS Reporting
鶹Ƶjoined 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.
鶹ƵSubmits Comments to EPA on Proposed PFAS Reporting
鶹Ƶsubmitted 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, 鶹Ƶunderscored 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.
鶹ƵLetter to California Law Revision Commission
鶹Ƶjoined a multi-association letter California Law Revision Commission raising concerns with potential efforts by California to establish a legal standard for merger review that impedes, contradicts, or otherwise departs from the standard set by federal law. 鶹Ƶbelieves such a move would risk disrupting national commerce, creating unnecessary regulatory burdens, and undermining the efficiency and predictability that businesses rely upon to operate and grow.
鶹ƵComments to CDPHE on Proposed Regs for Solid Waste Sites
鶹Ƶsubmitted comments to the Colorado Department of Public Health and Environment on revised Proposed Amendments to Section 18 of the Regulations for Solid Waste Sites and Facilities. In its comments, 鶹Ƶurged that the proposed definition of ‘small business’ be revised. 鶹Ƶalso pressed for the revised proposed amendments to provide that producers may request a hearing to contest any assessed dues.