The US EPA plans to hold a stakeholder meeting on EPA Rules that can be repealed, replaced or modified to reduce regulatory burdens under Executive Order 13777 Enforcing the Regulatory Reform Agenda. SGIA has submitted comments on these initiatives in response to a Notice for Public Comment issued by the US Department of Commerce. SGIA will be participating and offering public comments at the US EPA stakeholder meeting on environmental regulations that would benefit from streamlining. SGIA has long supported the development and implementation of programs and initiatives addressing the streamlining of regulations for printing operations. These efforts, once implemented, provide a cost-effective solution to compliance with all regulatory initiatives and most importantly, protection for the industry, environment, and our employee base. For more information, please contact Marci Kinter at firstname.lastname@example.org
Executive Order 13777, Enforcing the Regulatory Reform Agenda, was issued by President Trump on Feb. 24, 2017. In response to this EO, the US Department of Commerce issued a public notice in the March 7, 2017 Federal Register calling for the manufacturing base to submit comments on the “Impact of Federal Regulations on Domestic Manufacturing.” SGIA, in conjunction with the Printing Industries of America and Flexographic Technical Association, stated in its comments that printing trade associations have long supported the development and implementation of programs and initiatives addressing the streamlining of regulations for printing operations. These efforts, once implemented, provide a cost-effective solution to compliance with all regulatory initiatives and most importantly, protection for the industry, environment, and our employee base. For a complete copy of the comments submitted, please contact Marci Kinter at email@example.com.
On March 28, 2017 SGIA submitted comments to Utah’s Department of Environmental Quality regarding the state’s proposed rule on industrial solvent use. The state agency is proposing to remove all mentions of industrial cleaning solvents from their degreasing rule, R307-335. Furthermore, the proposed rule R307-304 is the new industrial cleaning solvent rule which adopts standards based on the recommendations of the EPA’s Industrial Cleaning Solvent Control Techniques Guidelines (CTG).
In our comments, we supported the proposed 500 g/L VOC limit for screen printing operations. Solvents are used in such key areas of the screen printing process, and as such it is essential that VOC limits are set at a reasonable level.
SGIA also recommended that the department exempt cleaning operations associated with digital printing. The CTG was first drafted in the 1990s and does not address digital printing or other emerging sectors. Due to this, other states have already exempted industrial cleaning assisted with digital printing from their own state VOC regulations.
SGIA continues to monitor this legislation. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
On March 22, 2017 SGIA attended the First 100 Days 2017 Legislative Conference, co-hosted by NPES and Idealliance. Members of both the United States House of Representatives as well as members of the printing, imaging, and mailing industry were invited to attend the conference.
The program included several panels on issues that could have a significant impact on the printing industry. With the new administration, there are expected to be many policy changes that printers should be aware of. Topics included healthcare reform, regulatory and workplace policy, trade policy, and tax policy.
The first panel focused on regulatory and workplace issues and highlighted the importance of small businesses to our country’s workforce. The healthcare panel discussed the American Health Care Act, which if passed would repeal the Affordable Care Act and make key changes such as tax credit structure changes, the phasing out of Medicaid, and the removal of penalty taxes for not having insurance. The third panel was focused on the Trump administration’s trade policy, which is one based on trade agreements to reduce the US trade deficit. The final panel focused on the tax policies of the new administration, which included discussion of the House Ways and Means Committee tax reform Blueprint.
SGIA will continue to monitor the impact of these policy changes. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
On March 14th, 2017, SGIA submitted comments to the Environmental Protection Agency regarding the proposed TSCA Inventory Reset rule. The proposed rule “resets” the Toxic Substances Control Act Chemical Substance Inventory, and provides procedures for classifying chemicals as either active or inactive.
According to the proposed rule, substances listed on the TSCA inventory that were manufactured in or imported to the United States for non-exempt commercial purposes between June 21, 2006 and June 21, 2016 must report to the EPA. This retrospective notification is required for manufacturers and optional for processors. When EPA is notified of the manufacture, importing, or processing of a chemical substance, that substance is designated as active. Substances that the EPA does not receive notices for are designated as inactive. Once a substance becomes inactive, it is unlawful to manufacture, import, or process using that chemical.
SGIA supports parts of the rule, such as not requiring processors to submit information. There were, however, other parts of the rule that SGIA was not able to support. As part of the reporting process, manufacturers are required to submit the exact dates that a product was manufactured or imported over the designated ten-year period. SGIA commented that this specific reporting requirement is unnecessary and that many businesses will not have that information. SGIA also commented in disagreement with the reporting requirements, which would give manufacturers the responsibility of retaining records of their submissions for five years. As EPA does not provide a basis for this requirement, SGIA requested that it be removed.
SGIA also commented that the EPA should be lenient on businesses who unintentionally submit incorrect information or who do not have all the required information. SGIA recommended that the EPA encourage follow-up reporting rather than penalizing these businesses.
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