鶹ƵJoint Letter on SEC Proposed Climate Reporting Rule
鶹Ƶjoined more than 50 other organizations in a letter to Congressional committee leaders on the SEC's proposed a new climate reporting regime that will impose substantial costs on manufacturers and interfere with their efforts to report decision-useful climate information to their investors.
鶹ƵComments on New York’s Proposed Hazardous Waste Revisions to the Universal Waste Rule
On Jan. 17, 鶹Ƶsubmitted comments to the New York State Department of Conservation on the agency's proposed hazardous waste management regulatory revisions. 鶹Ƶhas a significant interest in assisting our industry in pollution prevention strategies and compliance with RCRA requirements.
鶹ƵComments to EPA onTSCA Administration Fee Proposal
On Jan. 17, 鶹Ƶsubmitted comments to U.S. EPA on the agency's proposed changes to fees to administer the Toxic Substances Control Act (TSCA). ACA's comments made a number of suggestions for EPA consideration.
鶹ƵComments on EPA’s PFAS Reporting Rule IRFA
鶹Ƶsubmitted comments to U.S. EPA on the agency’s Initial Regulatory Flexibility Analysis and Updated Economic Analysis (IRFA) for the proposed rule, Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA).
Comments on PHMSA's Hazardous Materials Registration and Fee Assessment Program
鶹Ƶjoined the Interested Parties for Hazardous Materials Transportation in a letter to the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration on potential adjustments to the agency’s hazardous materials registration and fee assessment program.
ACA, Others Urge EPA to Extend PFAS Reporting Rule Comment Deadline
鶹Ƶjoined 17 other organizations in a letter to U.S. EPA requesting that the agency extend the comment period for the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule by 30 days.
Letter to Congressional Leadership for Action to Avert a Rail Strike
On Nov. 28, 鶹Ƶjoined more than 400 organizations in a letter to Congressional leadership urging action to avert a rail strike. “While a voluntary agreement with the four holdout unions is the best outcome, the risks to America’s economy and communities simply make a national rail strike unacceptable,” the letter stated. “Therefore, absent a voluntary agreement, we call on you to take immediate steps to prevent a national rail strike and the certain economic destruction that would follow.”
鶹ƵComments on Maine's Second Concept Draft for PFAS
On Nov. 10, 鶹Ƶsubmitted detailed comments to the Maine Department of Environmental Protection (DEP) on the Second Concept Draft for regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Pollution. 鶹Ƶcontinues to engage with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment.
鶹ƵJoins Coaltion Comments to EPA on Proposed RMP Amendments
鶹Ƶwas among 20 organizations that submitted joint comments to the U.S. EPA on the agency's Risk Management Program (RMP) proposed amendments. The detailed comments included several recommendations and other input for EPA consideration.
鶹ƵComments on EPA's Proposed RMP Amendments
ACA's Oct. 31 comments to EPA noted that many of the agency's proposed amendments to the RMP rule aim to improve upon prevention program elements of particular types of facilities, promote information availability, and emergency response measures, and that 鶹Ƶshares EPA’s goal of ensuring people both inside and outside of chemical facilities are safe and prevent any catastrophic chemical accidents. However, some of EPA’s proposed changes (as currently drafted) will not serve to improve the safety within a chemical facility, but rather create significant burdens on a facility that would result in higher costs to the facility with no corresponding improvement in safety.