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CPA Submits Comments on TSCA Title VI, Air Regulatory and Permit Reforms

Last week, CPA submitted two sets of comments in response to EPA’s request for information on regulations that could be repealed, replaced or modified to make them less burdensome. The first set of comments reinforced CPA’s longstanding support for TSCA Title VI and the need to level the playing field for North American manufacturers.  The comments also strongly urged EPA to make certain editorial changes as soon as possible to facilitate implementation of the regulation, such as removing the ban on truthful, voluntary labeling prior to the compliance date.  CPA reinforced to EPA that any other substantive changes to the Regulation, however, would require appropriate Administrative Procedure Act notice and comment rulemaking.

The second set of comments focused on air permitting and regulatory reforms, including most notably calling on EPA to set reasonable work practice standards in the upcoming Plywood Composite Wood Product (PCWP) MACT and Residual Risk and Technology Review, and to reduce the burden of its upcoming mill survey.  CPA also referenced comments submitted by the American Wood Council (AWC) in support of additional air permitting and regulatory reforms.  CPA continues to coordinate closely with AWC in pursuing these reforms.  Last week, Gary Heroux, along with CPA members and AWC staff and members, attended meetings with EPA in North Carolina on the PCWP MACT.  See CPA TSCA Title VI and Air Reform Comments.  More Info: Jackson Morrill and Gary Heroux

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