On Friday August 4, 2017, SGIA attended an Environmental Roundtable Meeting hosted by the Small Business Administration. The roundtable was open to the public and allowed small business stakeholders to discuss relevant environmental issues and regulations.
A major topic of discussion was EPA’s 2015 Definition of Solid Waste rule. This rule replaced the 2008 Definition of Solid Waste rule, and included provisions both to prevent the mismanagement of hazardous secondary materials intended for recycling and to promote recycling of these materials. The DC Circuit Court recently reviewed this rule as a result of petitions by industry stakeholders and made some key decisions regarding the rule.
The court invalidated the requirement that the concentrations of the recycled secondary product be comparable to the concentrations in the product or intermediate being replaced. The court also eliminated the “verified recycler exclusion”, which required EPA or a state agency to approve third party recycling facilities, and reinstated the 2008 requirement to use best efforts to identify a recycler that would follow sound environmental practices.
SGIA will continue to monitor these important policy issues. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
On July 21, 2017, SGIA attended a Small Business Labor Safety Roundtable hosted by the Small Business Administration in Washington, D.C. The roundtable provided a forum for small business stakeholders to discuss the current regulatory climate. Speakers from the SBA and the Department of Labor gave updates on key regulatory issues.
Nathan Mehrens of the DOL spoke about the current regulatory review and reform process taking place due to Executive Orders 13771 and 13777. The DOL will be putting together a “taskforce” to determine which rules under their jurisdiction should be repealed or modified. Some rules already undergoing the process for repeal are the DOL drug testing rule, OSHA’s continuing recordkeeping obligation, and the DOL’s rule on savings arrangements established by qualified state political subdivisions for non-governmental employees.
Bruce Lundegren of the SBA provided an update on a series Regional Regulatory Reform Roundtables that the Administration is holding. The first of the roundtables was held in June in New Orleans, where key topics included the DOL rule changes and supply chain issues. In June, a roundtable was held in Idaho where the SBA heard a lot from the mining and timber industries about their concerns. SBA will be hosting more of these roundtables in other cities in the coming months.
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On July 19, 2017 SGIA attended a Pennsylvania Department of Environmental Protection (PADEP) Public hearing in Pittsburgh, PA to give testimony on a proposed rule to control volatile organic compound (VOC) emissions from industrial cleaning solvents and additional RACT requirements for major sources of VOC’s.
The purpose of the hearing was for the PADEP to get input on how this proposed rule will impact relevant stakeholders.
At the hearing, SGIA expressed support for the PADEP’s statements that the rule will impact a significant amount of facilities and further pointed out that an estimated 850 screen and digital printing facilities operating in Pennsylvania would be impacted by the rules applicability threshold of 2.7 tons per 12 month rolling period.
During the testimony SGIA supported the PADEP’s proposed language in section (c) of the proposed rule which would list digital printing as an exempted category.
Finally, SGIA expressed agreement with the Department’s proposed language which would allow screen printing operations to utilize cleaning solvents with a VOC content of no more than 4.2 lbs. per gallon or 500 grams per liter. The use of this low VOC technology represents RACT for our industry sector and will align Pennsylvania’s rule with other state regulations.
SGIA continues to monitor this critical rulemaking. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
SGIA attended an energy forum hosted by the National Association of Manufacturers (NAM) on July 13, 2017. Melissa Simpson, Senior Advisor of the Bureau of Energy Resources at the U.S. Department of State, was the guest speaker of the event, which is part of a series of energy forums NAM will hold this year. Simpson provided attendees with a brief overview of her Bureau’s current projects and how they may affect manufacturers and others in the energy sector.
A prime goal of the Bureau, according to Simpson, is to expedite the process of providing presidential permits for border crossings. These permits allow gas and petroleum pipelines, as well as electrical transmission lines to cross the border between the U.S. and Mexico. The Bureau of Energy Resources receives permit applications for liquid petroleum and petroleum product pipelines. Simpson detailed that under previous administrations, these permits could take up to five years to obtain. The Bureau is working on speeding up this process so that more permits may be issued.
The speaker also stated that this Administration, along with the State Department, is willing to work with manufacturers in the United States to find the right contacts in Mexico and other countries, and are actively working with other countries to provide resources for things like solar energy and natural gas where they are needed.
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On June 23, 2017, SGIA submitted comments to the EPA on the assignment and application of unique identifiers under the Toxic Substances Control Act. Under TSCA, the Agency is required to assign a unique identifier to all chemicals for which a request for confidentiality is received. The EPA has requested comments on how to proceed with a proposal for this requirement.
SGIA submitted comments which supported provided a different unique identifier to each submission for confidentiality, rather than for each chemical. If each chemical received a unique identifier, and there were multiple submissions for a single chemical, it may lead to situations where confidential information is inadvertently made public. SGIA outlines the importance of confidential business information for successful companies in the comments submitted.
SGIA continues to monitor TSCA implementation. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.