On September 6, 2017 SGIA attended a House Committee on Small Business meeting, titled “Expediting Economic Growth: How Streamlining Federal Permitting Can Cut Red Tape for Small Businesses.” The purpose of the hearing was to address the growing number of overlapping federal laws and regulations that small businesses must comply with.
Several witnesses provided their views on federal permitting issues. Mr. Louis Griesemer, testifying on behalf of the National Sand Stone Gravel Association, commented that permitting regulations can delay projects and often these regulations can be contradictory, causing even more confusion and delays. Ms. Margot Dorfman, CEO of the Women’s Chamber of Commerce, stated that permitting regulations are there to protect people and the environment. Ms. Dorfman recommended that the SBA play more of role in working with Congress to streamline regulatory requirements for small businesses.
Some of the key takeaways from the discussion were that overlapping regulations are a big problem for small businesses, regulations are often too long and difficult to understand, and that there should be a clear line of authority to make decisions regarding regulatory compliance to avoid setbacks and confusion.
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From August 16-17, 2017 SGIA attended a Chemical Data Reporting (CDR) Inorganic Byproducts Meeting Negotiated Rulemaking Committee. The meeting was hosted by the EPA and held at the Agency’s office in Washington, D.C.
In December of 2016, the EPA published a notice in the federal register establishing its intent to establish a negotiated rulemaking committee and negotiate a proposed rule on chemical data reporting under section 8(a) of the Frank R. Lautenberg Chemical Safety for the 21st Century Act. To pursue this negotiation, the EPA formed a federal advisory committee composed of interested stakeholders from the EPA, tribes, states, environmental/health/public interest organizations, manufacturing industry associations and companies, and recycling industry associations and companies. The committee began meeting early in 2017 to begin negotiations.
At the August meeting, the committee discussed potential approaches for reporting requirements and identified strengths and concerns for each approach. A total of 6 approaches have been proposed, each offering a different solution to reporting. The most agreed upon approach seemed to be approach A, which simplifies reporting by removing the need to consider exemptions, enabling reporting in categories, and reporting reduced processing and use information, for inorganic byproducts that are recycled, reused, or reprocessed.
The committee did not come to an agreement, however, and has established smaller work groups to discuss different approaches before the next meeting in September. SGIA will continue to monitor this negotiated rulemaking. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
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.