ACA Comments on Maine’s EPR Program for Packaging
On Oct. 31, ACA submitted comments to the Maine Department of Environmental Protection regarding Maine’s Extended Producer Responsibility Program for Packaging. ACA's comments included recommendations that would streamline compliance requirements and offer greater clarity for the coatings industry.
ACA Supports Proposed Amendment to Ohio Evidence Rule 702
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.
NDAA FY24 PFAS Coalition Letter
ACA joined several organizations in a letter to Congressional Armed Services Committee leadership urging the removal of Section 333 from the final National Defense Authorization Act for Fiscal Year 2024 conference agreement that would restrict procurement of certain products containing PFAS.
ACA Comments on California DTSC Proposal for Microplastics
ACA submitted comments to the California Department of Toxic Substances Control (DTSC) regarding the agency’s proposal to add microplastics to its Candidate Chemicals List under the Safer Consumer Products Program.
ACA, Coalition Opposition to PFAS-Free Procurement Act of 2023
ACA joined a coalition letter to Congressional leadership, urging withdrawal of S. 2283, from consideration at the Homeland & Government Affairs Committee’s business meeting on July 26. “This legislation, which was just introduced on July 12, 2023, involves serious and complex issues that require more education, deliberation, and engagement among all stakeholders.”
ACA Supports Immediate Reauthorization of CFATS Program
ACA letters to Congressional leadership for the House and Senate on the Committees on Homeland Security and Governmental Affairs urged immediate passage of legislation to reauthorize the Chemical Facility Anti-Terrorism Standards (CFATS) program. The U.S. Department of Homeland Security (DHS) implements the CFATS program under a variety of short-term authorizations by Congress; and authorization for the current CFATS standards will expire after July 27, 2023, if Congress does not reauthorize the program.
ACA Letter to Senators on Federal PFAS Bill
ACA sent a letter to U.S. senators on a bipartisan bill addressing PFAS that aims to provide a consistent and practical definition of PFAS compounds for use by federal agencies, state governments, and other entities. ACA supports the exclusion of polymers in the proposed definition as it helps to focus regulatory efforts on compounds based upon their potential for presence in the environment and human exposure.
ACA Comments on EPA’s Proposed Methylene Chloride risk Mitigation Rule
In its comments, ACA asked EPA to consider several suggestions, including that the agency consider the risk mitigation strategies typically used in industry when conducting a risk evaluation and during risk mitigation.
ACA Recommends Exemptions for Oregon’s EPR Covered Products
ACA submitted comments to the Oregon Environmental Quality Commission and the Oregon Recycling Council on possible exemptions allowed under the Plastic Pollution and Recycling Modernization Act.
ACA, Coalition Comment on Northeast Waste Management Officials Association Draft Legislation
ACA and several other organizations commented on NEWMOA model legislation related to preventing PFAS releases into the environment. While supporting this goal, the comments note that as drafted, the model legislation would create an overly burdensome reporting requirement and a ban on all PFAS-containing products— a misguided approach that could ultimately harm consumers and businesses while straining agency resources in states that might enact such a policy.