ACA Comments on OSHA’s Proposed Emergency Response Standard
ACA's comments focused on Workplace Emergency Response Employers, and generally expressed concern that the covered emergency activities are unnecessarily broad, adressing relatively minor emergency responses.
ACA, Coalition Oppose Extension for Detention and Demurrage Billing Requirements Final Rule
ACA joined more than 60 organizations expressing strong opposition to the petition filed by the Ocean Carrier Equipment Management Association to extend the effective date of the Detention and Demurrage Billing Requirements Final Rule. The coalition letter urged the Federal Maritime Commission to reject the petition.
ACA Supports California SB 1143, PaintCare Expansion
The bill makes technical but important changes to California’s PaintCare architectural paint recovery program. Specifically, the proposed changes incorporate non-industrial coatings and coatings-related products as product categories that can be managed under the scope of California’s existing PaintCare program.
ACA, Coalition Urge Support for the Regulatory Early Notice and Engagement Act
ACA joined a coalition letter to members of Congress urging sponsorship and support for H.R. 8204, the Regulatory Early Notice and Engagement Act. This bipartisan legislation would reform the federal regulatory process to make it more transparent, accountable, and responsive to the public.
ACA Comments to Nevada's Clark County Department of Environment & Sustainability on Proposed AIM Coatings Rule
In its comments ACA urged a compliance date of at least one year from the date of final rule adoption, as well as sell-through provision for three years after the effective date of the final rule.
ACA Responds to EPA’s Request on Unpublished Health and Safety Studies
EPA is proposing to add 16 chemical substances to lists at 40 CFR 716.120, triggering a reporting requirement within 90 days of finalizing the rule. Chemical substances include those undergoing prioritization and chemicals that EPA may select for future prioritization. Manufacturers and importers would be required to submit health and safety studies “known to” them or lists of studies where appropriate, including studies describing physical characteristics, environmental degradation, general population monitoring, etc.
ACA, Coalition ask FTC to Stay and Delay Implementation of the Noncompete Rule
ACA joined a coalition letter sent to the U.S. Federal Trade Commissioners requesting that the FTC stay the effective date of the Non-Compete Clause Final Rule (89 Fed. Reg. 38,342-38,506, “Noncompete Rule”) to allow for judicial review.
ACA Submits Comments to USGBC on LEED v5
This letter consolidates ACA’s comments to U.S. Green Building Council (USGBC) on LEED v5, which is the newest version of LEED. LEED (Leadership in Energy and Environmental Design) is the world's most widely used green building rating system and is globally recognized as such.
ACA, Coalition Urge Exclusion of Certain PFAS Provisions from FY 25 NDAA
ACA joined a coalition letter to Congressional leaders on the Armed Services Committees urging them not to include provisions in the National Defense Authorization Act for Fiscal Year 2025 (FY 25 NDAA) that would circumvent the existing legal and regulatory processes for per- and polyfluoroalkyl substances (PFAS).
ACA Comments on EPA’s Proposed Risk Evaluation of Formaldehyde
In its comments ACA noted that evaluating paints and adhesives separately from processing formaldehyde into resins would provide a more accurate assessment.