鶹ƵWritten Testimony on Rhode Island House Bill 6207
鶹Ƶsubmitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety (HB 6207). 鶹Ƶrecommended that the definition of ‘exempt materials’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6207.
鶹ƵWritten Testimony on Rhode Island House Bill 6205
鶹Ƶsubmitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act (HB 6205). 鶹Ƶrecommended that the definition of ‘packaging’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6205.
鶹ƵProvides Feedback to OMB on Deregulation
鶹Ƶresponded to the White House Office of Management and Budget's solicitation for comments on potential deregulation for industry. 鶹Ƶhighlights elements of regulatory frameworks that have particularly onerous requirements and present unnecessary challenges for industry. These include certain regulatory provisions under the Toxic Substances Control Act, Emergency Planning and Community Right to Know Act, and Federal Fungicide Insecticide and Rodenticide Act; EPA’s National Volatile Organic Compound Emission Standards for Aerosol Coatings Amendments; EPA’s Universal Waste Rules; Build America, Buy America Act; and EPA's recent amendments to the Risk Management Program.
鶹ƵComments on New Jersey Assembly Bill 5009
鶹Ƶsubmitted written testimony to the New Jersey Assembly Standing Committee on Environment, Natural Resources, and Solid Wastes, regarding Assembly Bill 5009 – An Act Concerning the Disposal of Packaging Products. 鶹Ƶurged the legislature to amend the bill to include additional exemptions commonly found in other states’ packaging extended producer responsibility laws. 鶹Ƶmaintains that doing so would promote ease of compliance by industry.
鶹ƵComments on Massachusetts House Bill 926
鶹Ƶsubmitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on House Bill 926 – An Act to Save Recycling Costs in the Commonwealth. 鶹Ƶrecommended that the legislature amend the definition of ‘packaging’ to include additional exemptions commonly found in other states’ packaging Extended Producer Responsibility laws, to provide consistency and promote ease of compliance for industry.
鶹ƵComments on Massachusetts Senate Bill 571
鶹Ƶsubmitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on Senate Bill 571 – An Act to Reduce Waste and Recycling Costs in the Commonwealth. 鶹Ƶrecommended that the legislature amend the definition of ‘packaging’ to include additional exemptions commonly found in other states’ packaging Extended Producer Responsibility laws, to provide consistency and promote ease of compliance for industry.
鶹ƵComments on Illinois Universal Waste Regulations for Paint
鶹Ƶsubmitted comments to letter to the Illinois Pollution Control Board regarding the state's proposed universal waste management regulations for paint and paint-related wastes. ACA's comments focused on ACA's forthcoming PaintCare program in the state.
鶹ƵTestimony on Rhode Island SB 930
鶹Ƶsubmitted written testimony to Rhode Island Senate Environment and Agriculture Committee regarding Senate Bill 939, An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act. 鶹Ƶurged the Senate to amend the definition of ‘packaging’ to clarify that packaging for products subject to the state's PaintCare post-consumer paint program are not covered materials under SB 939.
鶹ƵSupports Litigation Transparency Act of 2025
鶹Ƶjoined a coalition of organizations in a letter to Congress supporting H.R. 1109, the Litigation Transparency Act of 2025. The bill seeks to enhance transparency and oversight of third-party litigation funding (TPLF) by putting in place a uniform disclosure requirement of TPLF in all federal civil litigation. TPLF, an increasingly prevalent multi billion-dollar industry, allows hedge funds, sovereign wealth funds, foreign entities and other financiers to secretly invest in lawsuits in exchange for a share of the settlement or award.
鶹ƵComments on EPA's Proposed Mitigation Rule for Pigment Violet 29
In its comments submitted to the U.S. Environmental Protection Agency, (EPA) 鶹Ƶrecommended that EPA revise its underlying risk evaluation of Pigment Violet 29 to more accurately assess risk with an accurate exposure value, if needed, while considering current handling and practices in its exposure evaluation.