This ECOS letter to U.S. EPA outlines questions states intend to raise at the agency’s National Leadership Summit to address Per- and Polyfluoroalkyl Substances (PFAS). Of upmost importance is the collective states’ view that the federal government should take a leadership role in protecting public health, informing citizens, and supporting state action to address these…
Policy Documents
Letter to U.S. EPA on Prioritization of Mercury under TSCA
This letter details ECOS’ request for U.S. EPA to designate mercury and mercury compounds as priority chemicals under the Lautenberg Act.
ECOS Comments on Draft Guide for Access to TSCA CBI
These comments reflect state views on U.S. EPA’s draft guidance for access to TSCA Section 14(d)(4) Confidential Business Information.
ECOS Letter to Congress on Preserving the U.S. EPA’s IRIS
This letter urges Congress to support retaining the U.S. EPA’s Integrated Risk Information System (IRIS) Program’s funding and personnel with the Office of Research and Development (ORD). Retaining IRIS within ORD will help to ensure that state public health and environmental protection programs can continue to rely on IRIS’ invaluable and impartial health hazard assessments.
ECOS Comments on Reporting Requirements for the TSCA Mercury Inventory
This letter outlines ECOS’ Comments submitted under Federal Docket EPA-HQ-OPPT-2017-0421 (82 FR 49564) on reporting requirements for the TSCA Mercury Inventory. ECOS urges EPA to adopt mercury reporting requirements for the TSCA Mercury Inventory that will ensure fulfillment of the statutory requirements under TSCA’s 2016 amendment, the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
ECOS Comments on TSCA Chemical Data Reporting Requirements for Inorganic Byproducts
This comment letter, submitted on December 11, 2017, outlines ECOS’ recommendations to U.S. EPA on the chemical data reporting (CDR) requirements for the inorganic byproduct chemical substances negotiated rulemaking process and on the associated Federal Advisory Committee. ECOS also submitted an appendix to the comments, here, which discusses options considered by the negotiated rulemaking committee…
ECOS Comments on EPA’s FY18-19 National Program Manager Guidances
This letter and corresponding document contain ECOS’ comments on U.S. EPA’s draft Fiscal Year (FY) 2018-2019 National Program Manager (NPM) Guidances for the OLEM, OAR, OCSPP, OW, OEI, OITA, OECA, and NEPPS offices.
Resolution 17-1: Advancing Safer Chemical Products and Processes
This resolution encourages support for sustainable and green chemistry and the promotion of alternatives assessment.
ECOS Charter for the Toxic Substances Reduction Workgroup
Below is the charter establishing ECOS’ Toxic Substances Reduction Workgroup, which will fall under the auspices of the Cross-Media Committee.
Resolution 16-3 On Implementing the Toxic Substances Control Act Reforms
In this resolution, ECOS urges EPA to ensure it has resources to implement TSCA reform; urges timely consultation and coordination with states on prioritization of chemicals for risk evaluation, and implementation of risk determinations; and urges states and EPA to maintain a dialogue so that proper regulation of chemicals is not limited by preemption, confidential…
