While we look at these new opportunities on the horizon, we must be equally mindful of preserving existing industry vitality. ACMA has long had a robust regulatory and compliance program where we work to help our industry navigate complex federal, state and local rules, as well as weigh in with agencies to ensure composites are appropriately understood and regulations are not overly burdensome.
ACMA will continue watching EPA’s Toxic Substances Control Act (TSCA) program as it evaluates the health risks of formaldehyde and other substances. While formaldehyde is not widely used in the composites industry, EPA’s review of the health effects data for this substance may provide important indications of how the agency will approach styrene, which is on the priority list for assessment by this program.
In 2020, we expect resolution of claims by Bayer and other organizations that California EPA erred when classifying the herbicide glyphosate as a carcinogen under Prop 65. If the court decides in favor of the plaintiffs, this may support the composites industry’s attempt to settle enforcement related to emissions of styrene by several California composites manufacturers.
The draft of the 2022 Edition of NFPA 400 will become available for review this year, allowing ACMA to evaluate the impact of proposed new fire code provisions for storage and use of organic peroxides. Especially important will be an assessment of proposed requirements for storage of smaller quantities of organic peroxides in what the code calls “control areas”.
EPA is expected to release its final rule establishing risk and technology review (RTR) standards for composites manufacturing operations. These are controls or practices the agency determines are necessary beyond those required under the 2003 MACT standard necessary to protect public health. In the proposed composites manufacturing RTR standard issued in early 2019, EPA did not determine that there is a public health risk caused by composites manufacturing emissions necessitating implementation of new control requirements.
Whether on the Hill or in regulatory agencies, what drives our agenda is member involvement. If you are involved in the infrastructure market, your company has everything to gain by attending our 2020 Infrastructure Day, Feb. 12-13 in Washington, D.C. We bring you personal meetings with members of Congress to lobby for these key issues, as well as your company’s other priorities. We also provide insider presentations from senior government officials. Early 2020 is an essential time to engage, and Congress needs to hear from you.