Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Urges Immediate CFATS Reauthorization

ACA and 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.

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ACA & PaintCare Submit Universal Waste Petition to EPA

In this petition to U.S. EPA, ACA and 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.

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ACA Comments to Washington DOE on Draft Report for Antifouling Paints

ACA has 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.

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ACA Supports 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. ACA supports 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.

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ACA Comments on Prop 65 Short-Form Proposal

ACA submitted 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.

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ACA Letter on Antidumping of Tin Mill Products

ACA signed 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.

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ACA Comments on EPA's Used Drum Management and Reconditioning ANPRM

ACA and 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 ACA encourages EPA to develop non-regulatory guidance to promote compliance with the existing regulations," ACA comments read.

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ACA Encourages Congress to Act on Miscellaneous Tariff Bill

ACA joined some 200 organizations and businesses urging Congress to act this year on critical and long overdue trade legislation to provide U.S. businesses with a robust set of tools to compete with China and other countries around the world. The MTB, which temporarily reduces or eliminate tariffs on products that are not available in the U.S., has been expired since December 2020. Since then, manufacturers and other businesses have paid more than $1.4 billion in anti-competitive tariffs.

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