Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
Click ‘Read More,’ to open the PDF, with the option for download.

Washington State Department of Ecology’s New Safer Products for Washington Program

ACA signed onto a multi-organization letter to express concern regarding the Washington State Department of Ecology’s new Safer Products for Washington regulatory program, authorized by legislation enacted in 2019. "While Ecology’s report, which will likely contain recommendations to prohibit specific chemistries will be finalized in June, key elements contained in the draft report issued last November, are raising serious concerns for
our respective industries and will have unintended consequences for the long-term safety and availability of products in Washington State."

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House Support for America COMPETES Act and the USICA

As Congress begins the conference process to reconcile the differences between the America COMPETES Act and the U.S. Innovation and Competition Act (USICA), ACA requests House of Representatives’ support of the following: a robust Miscellaneous Tariff Bill (MTB) with full retroactivity’ inclusion of the full $52 billion for CHIPS for America Act; and funding to improve our nation’s supply chains.

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Senate Support for America COMPETES Act and the USICA

As Congress begins the conference process to reconcile the differences between the America COMPETES Act and the U.S. Innovation and Competition Act (USICA), ACA requests Senate support of the following: a robust Miscellaneous Tariff Bill (MTB) with full retroactivity’ inclusion of the full $52 billion for CHIPS for America Act; and funding to improve our nation’s supply chains.

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Comments to OEHHA on Proposed Amendments to Prop 65 Short-Form Warnings

ACA was among more than 40 organizations that submitted comments to the California Office of Environmental Health Hazard Assessment regarding the agency’s second modification of Text Title 27, California Code of regulations Proposed Amendments to Article 6 Clear and Reasonable Warnings - Short Form dated April 5, 2022. The group requested that the Proposed Rulemaking be withdrawn in its entirety or at least modified as suggested in the detailed comments.

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Opposition to California AB B 2247 Proposing New Database for Manufacturers re. PFAS Substances

ACA was among more than 20 organizations in a letter opposing Califiornia AB 2247 (as amended), legislation proposing the creation of a new database to house information submitted by manufacturers relative to perfluoroalkyl and polyfluoroalkyl (PFAS) substances. "Collectively, we support the responsible production, use and management of fluorinated substances, including regulatory requirements that are protective of human health and the environment, taking into consideration the diversity of physical and chemical properties and the environmental and health profiles of these substances. With respect to AB 2247, the bill imposes a significant new reporting requirement on businesses but delegates virtually all the implementation activities including creating a database and managing the information collected to a 3rd party entity."

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