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Letters & Comments

Read ԹϺ’s letters and comments submitted to regulatory bodies and elected officials.
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Letter to Congressional Leadership for Action to Avert a Rail Strike

On Nov. 28, ԹϺ joined more than 400 organizations in a letter to Congressional leadership urging action to avert a rail strike. “While a voluntary agreement with the four holdout unions is the best outcome, the risks to America’s economy and communities simply make a national rail strike unacceptable,” the letter stated. “Therefore, absent a voluntary agreement, we call on you to take immediate steps to prevent a national rail strike and the certain economic destruction that would follow.”

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ԹϺ Comments on Maine's Second Concept Draft for PFAS

On Nov. 10, ԹϺ submitted detailed comments to the Maine Department of Environmental Protection (DEP) on the Second Concept Draft for regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Pollution. ԹϺ continues to engage  with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment.

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ԹϺ Comments on EPA's Proposed RMP Amendments

ԹϺ's Oct. 31 comments to EPA noted that many of the agency's proposed amendments to the RMP rule aim to improve upon prevention program elements of particular types of facilities, promote information availability, and emergency response measures, and that ԹϺ shares EPA’s goal of ensuring people both inside and outside of chemical facilities are safe and prevent any catastrophic chemical accidents. However, some of EPA’s proposed changes (as currently drafted) will not serve to improve the safety within a chemical facility, but rather create significant burdens on a facility that would result in higher costs to the facility with no corresponding improvement in safety.

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ԹϺ Letter Urges President to Work with Railroads and Unions to Ratify Tentative Agreement

ԹϺ joined more than 300 trade associations in a letter to President Biden urging continued "work with the railroad unions and railroads to ensure that the tentative agreement that you helped broker is ratified by the parties. It is paramount that these contracts now be ratified, as a rail shutdown would have a significant impact on the U.S. economy and lead to further inflationary pressure."

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ԹϺ Comments on MI EGLE VOC RACT Rule

On Oct. 26, ԹϺ submitted comments to the Michigan Department of Environment, Great Lakes, and Energy (MI EGLE) on the department's proposed VOC RACT Rule. Among its comments, ԹϺ asked the agency to dopt a compliance date of one year from the date of adoption of a final rule for the various coatings rules included in the proposed VOC RACT Rule (Part 6).

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ԹϺ Comments on PHMSA Information on Electronic Hazard Communication Alternatives RFI

On Oct. 24, ԹϺ responded to the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding its request for information on electronic hazard communication alternatives. In its comments, ԹϺ expressed support for an electronic alternative would provide for a more efficient and effective means to exchange information between shippers and transporters, especially in multi-modal operations.

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World Coatings Council Supports WHO International Lead Poisoning Prevention Week of Action

The World Coatings Council (WCC) supports the World Health Organization’s (WHO) International Lead Poisoning Prevention Week of Action, Oct. 23-29, 2022. During the campaign week, the Global Alliance to Eliminate Lead Paint (also known as the Lead Paint Alliance or LPA) reminds governments, civil society organizations, health partners, industry, and others of the unacceptable risks of lead exposure and the need for action. The campaign builds on the success in outlawing the use of lead in petrol and the progress achieved by many countries in establishing laws that limit the use of lead in paint, particularly those paints to which children are exposed in their homes, schools, and playgrounds. WCC applauds the WHO’s “say no to lead poisoning” campaign.

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ԹϺ, Others Seek RMP Proposed Rule Comment Extension

On Oct. 4, ԹϺ along with several other organizations asked U.S. EPA to provide a minimum 60-day extension of the comment period on EPA’s
“Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention” proposed rule. "Given the complex nature of the policy, economic, and technical issues raised in the notice and interaction with other agency regulations, an extension would assist our organizations and other commenters in providing thoughtful, considered comments on the notice."

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ԹϺ, Coalition Seek Comment Extension on EPA Proposal for PFOA/PFOS under CERCLA

On Sept. 13, ԹϺ and a collation of other organizations submitted a letter to U.S. EPA requesting an additional 60-day extension of the deadline for public comment on EPA’s proposed rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The same extension was requested with respect to the accompanying Economic Assessment of the Potential Costs and Other Impacts of the proposed rulemaking.

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