鶹ƵSupports Clarification of Build America, Buy America Requirements
In its letter to the U.S. House Committee on Transportation and Infrastructure Subcommittee on Highways and Transit, 鶹Ƶexpressed support for efforts to better understand the current administration’s implementation of Build America, Buy America, including those provisions that were in the Infrastructure Investment and Jobs Act.
鶹ƵUrges Immediate CFATS Reauthorization
鶹Ƶand a coalition of other organizations urged Congressional leadership to reauthorize the critical Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS) program that expired July 28, 2023. The CFATS program's primary mission is to help reduce the risk of a terrorist attack on the highest-risk chemical facilities by addressing a wide range of potential threats by bad actors.
鶹Ƶ& PaintCare Submit Universal Waste Petition to EPA
In this petition to U.S. EPA, 鶹Ƶand PaintCare request that that paint wastes be designated “universal waste” under 40 CFR Section 273. This rulemaking petition formally requests EPA to consider adding paint wastes to the federal universal waste rule. Although paint wastes are not currently on the federal universal waste rule, several states have implemented state-level universal waste rules to include paint wastes. Including paint wastes under the federal universal waste rule would not only ease the regulatory burden experienced by paint manufacturers, paint retailers, paint haulers, and paint recyclers by streamlining management standards, but also promote diverting these wastes from solid landfills.
鶹ƵSupports the Tax Relief for American Families and Workers Act
The Tax Relief for American Families and Workers Act will restore three tax policies vital to workers and America’s future: immediate expensing of domestic R&D expenses, enhanced interest deductibility, and 100% accelerated depreciation.
鶹ƵComments to Washington DOE on Draft Report for Antifouling Paints
鶹Ƶhas submitted comments to the Washington State Department of Ecology (DOE) draft report to the state legislature regarding antifouling paints. Notably, DOE's draft report highlights the importance of ensuring that there are safe and efficacious antifouling paint products for sale and use in Washington state.
鶹ƵSupports Proposal to Align Ohio Rule of Evidence 702 Updated Federal Counterpart
The proposed amendment to Ohio Rule 702 clarifies that the proponent of expert testimony must demonstrate “to the court that it is more likely than not” that the rule’s existing admissibility requirements are met. The amendment underscores the need for judges to act as “gatekeepers” against the admission of unreliable expert testimony. 鶹Ƶsupports this amendment because clarifying the Ohio rule will help avoid misapplication of the rule that has occurred with the analog federal rule and will promote harmony in Ohio’s state and federal courts.
鶹ƵComments on Prop 65 Short-Form Proposal
鶹Ƶsubmitted comments to the California Office of Environmental Health Hazard Assessment on the proposed amendments to short-form warnings under Article 6 of regulations implementing the California Safe Drinking Water and Toxic Enforcement Act — Proposition 65.
鶹ƵComments on Vermont’s Household Hazardous Waste EPR Guidance Documents
鶹Ƶsubmitted comments to the Vermont Department of Environmental Conservation on the state's guidance documents relating to its Extended Producer Responsibility (EPR) law for household hazardous waste. ACA's comments sought clarification on the department's guidance germane to covered products, FAQs, and more.
鶹ƵLetter on Antidumping of Tin Mill Products
鶹Ƶsigned onto a letter sent to U.S. International Trade Commission and International Trade Administration leadership regarding the anti-dumping investigations of tin mill products. "As you continue your antidumping duty investigations into tin mill products from eight countries, including key U.S. allies and partners, the undersigned organizations remain concerned that the imposition of new tariffs is not supported by market dynamics, including the reason for subject imports. The imposition of duties without merit would degrade the role of a fair trade remedy process in protecting U.S. manufacturers, while leading to higher consumer costs and the loss of thousands of good American manufacturing jobs in the can and consumer product manufacturing industries.
鶹ƵComments on EPA's Used Drum Management and Reconditioning ANPRM
鶹Ƶand the coatings industry believe the existing regulatory framework for the management of used industrial containers works. "However, if the agency determines that action needs to be taken, then 鶹Ƶencourages EPA to develop non-regulatory guidance to promote compliance with the existing regulations," 鶹Ƶcomments read.