ACA Comments on EPA's Proposed Interim Decision for Diuron
EPA published its Proposed Interim Registration Review Decision for Diuron in March 2022, adopting and referencing EPA’s Response to Comment on the Draft Risk Assessment for Diuron, having published the underlying Draft Risk Assessment (DRA) for Diuron in December 2020. ACA had provided comment on the DRA, noting deficiencies in data used to assess consumer and professional painter exposures during spray application of paint and worker exposure from open pouring of biocides during paint formulation.
ACA Comments on Maine Concept Draft for PFAS Reporting Implementing LD 1503
ACA submitted comments to the Maine Department of Environmental Protection (DEP) on the Concept Draft regarding regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances Pollution, 38 M.R.S. §1614. "We are committed to working with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment."
ACA Comments via Downstream Users Coalition on EPA Proposed Risk Mitigation Rule on Asbestos (Asbestos I Risk Evaluation)
ACA joined the Alliance for Automotive Innovation, Forest & Paper Association, Motor & Equipment Manufacturers Association, National Automobile Dealers Association, Toy Association, and the U.S. Tire Manufacturers Association to provide comments on the U.S. EPA's first risk management proposal issued after the passage of the Lautenberg Chemical Safety Act (LCSA).
ACA Comments on EPA Proposed Rule for Claiming CBI under TSCA
ACA supports and commends EPA’s initiative in developing a proposed regulations affecting assertion, EPA review, and treatment of confidentiality claims. ACA’s concerns relate to providing claimants with an adequate opportunity go engage with the agency to provide supplemental information and corrections.
Extension Request to Maine for PFAS Reporting Deadline 38 MRSA Section (3)
ACA was among several organizations that signed onto a letter requesting an extension of the deadline for reporting of products containing intentionally added substances defined as PFAS in the State of Maine that is scheduled to go into effect on January 1, 2023. “ We respectfully request the extension of the reporting deadline for the following reasons: The delay in rulemaking makes it difficult for manufacturers and companies to come into compliance, with a reporting deadline in less than six months.”
ACA Comments: EPA Proposed Reporting Rule for Asbestiform Minerals
ACA submitted comments on U.S. EPA's proposed reporting and record-keeping requirement for manufacturers, importers and processors of asbestos, including asbestos in bulk form, mixtures with asbestos or trace contaminants of asbestos and asbestos in articles, where activities occurred in the four years prior to the effective date of the rule.
EPA Proposal for Revising ‘VOC’ under CAA to Exclude Certain Hydrofluorocarbon Compounds
ACA signed onto a letter to U.S. EPA, providing comments on a specific question raised in the agency proposal to revise the regulatory definition of volatile organic compounds (VOC) under the Clean Air Act to exclude certain hydrofluorocarbon compounds. “ We believe that this rulemaking does not provide a proper vehicle for broadly examining questions about the diverse properties of PFAS chemistries, particularly regarding properties that are not related to the VOC exemption program.”
Designating PFOA and PFOS as CERCLA Hazardous Substances
ACA signed onto a multi-organization letter submitted to U.S. EPA Adminstrator Regan regarding support policy and practical solutions that will accelerate the cleanup of per-and polyfluoroalkyl substances (PFAS) in the environment. "As the U.S. Environmental Protection Agency (EPA) undertakes a rulemaking process to potentially designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), we write to express our concern over the unintended consequences this action could have on communities and companies nationwide."
Supporting Final Passage of the Ocean Shipping Reform Act
ACA signed onto a letter to Congressional leadership urging final passage of the Ocean Shipping Reform Act (S. 3580/H.R. 4996). “As U.S. companies continue to face ongoing supply chain disruptions and congestion in addition to rising inflation, it is critical for Congress to address these issues. Final passage of OSRA will help address the longstanding, systemic supply chain and port disruption issues that existed prior to the pandemic as the industry has changed significantly since the last time the Shipping Act was amended over 20 years ago.”
Excluding Select PFAS Provisions from FY 2023 NDAA
ACA signed onto a letter to Senate and House Armed Services Committee leadership urging them not to include provisions in National Defense Authorization Act for Fiscal Year 2023 (FY 23 NDAA) that would circumvent the existing regulatory process for PFAS. This includes provisions that would further restrict the procurement of PFAS-containing products and call for imposition of disposal and incineration restrictions by the Department of Defense that could prevent effective cleanups and hamper timely protection of human health.