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Society of Chemical Manufacturers & Affiliates Letter to Chairman Issa - January 10, 2011

Society of Chemical Manufacturers & Affiliates Letter to Chairman Issa - January 10, 2011

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Published by CREW
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 businesses, associations, and think tanks asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 businesses, associations, and think tanks asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.

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Published by: CREW on Jan 24, 2011
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04/06/2012

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January 10, 2011The Honorable Darrell E. IssaChairmanCommittee on Oversight and Government ReformU.S. House of Representatives2157 Rayburn House Office BuildingWashington, DC 20515-6143Dear Chairman Issa:The Society of Chemical Manufacturers and Affiliates (SOCMA) appreciates the opportunityto provide you, at your request, with existing and proposed regulations that have negativelyimpacted job growth in our industry. SOCMA is the U.S. trade association representingspecialty, batch, and custom chemical manufacturers, which collectively employ over100,000 workers in 2,000 sites and contribute $60 billion annually to our economy inproducts manufactured. Our membership includes many small manufacturers but also somemultinational companies. U.S. batch producers are highly innovative and are at the cuttingedge of new technology, providing products often made nowhere else in the world. The depthand expertise of this industry sector are vital components of the U.S. chemical industry andcontribute significantly to U.S. global competitiveness.SOCMA welcomes
Congress’ interest in examining existing and proposed regulations that
negatively impact the economy and jobs. In fact, last year SOCMA called on policymakersand administration leaders to cease, for the remainder of the year, further consideration oradvancement of legislation that would add to the regulatory burden facing smallmanufacturers.
 
SOCMA’s request was spurred, in part, by the high unemployment rate, the
tendency in Washington to grow regulatory burdens, and evidence that smaller companiesbear a disproportionate cost to comply with federal laws. According to 2005 research by theSmall Business Administration (SBA), small companies face an annual regulatory cost of $7,647 per employee, which is 45 percent higher than the regulatory cost facing large firms.Compliance with environmental regulations, like those issued by the U.S. EnvironmentalProtection Agency (EPA) under the Toxic Substances Control Act, costs 364 percent more forsmall companies.Many of the job-impacting regulations our members face are implemented or have beenproposed by the U.S. EPA, including two of the three regulations that we highlight below.
 
2
EPA’s Proposed Maximum Achievable Control Technolog
y Rule for Industrial,Commercial and Institutional Boilers and Process heaters.
 
This proposed “Boiler MACT”
rule, which seeks to reduce emissions of certain hazardous air pollutants from major sources inthis category, could impose billions of dollars in capital and operating costs at thousands of facilities across the country at a time when our already hurting manufacturing sector can least
afford such costs. An accompanying rule that targets smaller, “area” source boilers
will affecteven more SOCMA members, and could impose a very significant regulatory burden if theproposed exemption for natural-gas fired boilers is removed.We at SOCMA support efforts to address significant health threats from air emissions in a cost-effective manner, but also believe that this can be done while still protecting jobs and economicgrowth.Regarding the MACT rule, SOCMA shares the concerns of numerous other industry groups thatseveral of the standards proposed by EPA
 – 
such as those for dioxin, mercury, and carbonmonoxide, cannot be met in practice by even the best-performing boilers and process heaters.
These unachievable standards resulted from the agency’s improper pollutant
-by-pollutantapproach and an inadequate database. We also believe the agency should adopt a health-basedemissions approach for qualifying low-risk emissions. The agency acknowledged that its initialproposal was deeply flawed in its recent court request for an extension until April 2012 (from thelooming January 16 court-ordered deadline) so that it can repurpose the rule.
EPA’s Chemical Manufacturing Area Sources Final Rule.
This rule, which was finalized inresponse to a court order in October 2009, establishes national emission standards for hazardousair p
ollutants from smaller, “area” chemical manufacturing sources. It will impact the vast
majority of SOCMA members.While the final rule was an improvement from the initial proposal
 – 
a cost impact studycommissioned by SOCMA helped persuade the agency to alter some of the most egregiousprovisions in the proposed rule
 – 
SOCMA believes that it still is excessively burdensome and
costly. For example, the rule incorporates a “family of materials” concept that unnecessarily
limits operational flexibility. The agency also refused to establish a comprehensive de minimisthreshold, which could have exempted some of our smaller emitters from the burdens of the rule.Finally, the final rule includes numerous challenging provisions which were not contained in theproposal rule, thereby depriving us of the opportunity to comment on those provisions. Onesuch provision would require certain area sources to get a costly Title V permit. The agency has
acknowledged the validity of our concerns about these “surprise”
provisions; last summer, itaccepted our petition for reconsideration and will be proposing a revision to the rule.
OSHA’s Occupational Injury and Illness Recordkeeping Proposed Rule.
This proposalwould require employers to record employee musculoskeletal disorders (MSDs) in their OSHA300 recordkeeping log. SOCMA is concerned that this rulemaking is a backdoor way of revivingthe ergonomics rule that OSHA issued in 2001 and that Congress subsequently invalidated.Because of the uncertainty about how MSDs should be defined and the difficulty of determiningwhen an MSD is workplace-related, OSHA underestimates the cost to employers to comply withthis additional recordkeeping. Specifically, OSHA has not sufficiently accounted for burdens on

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