Mon April 3, 2017

As directed by the January 24, 2017 Presidential Memorandum, “Streamlining Permitting and Reducing Regulatory Burdens for Domestic Manufacturing”, the U.S. Department of Commerce issued a request for information (RFI) “on the impact of Federal permitting requirements on the construction and expansion of domestic manufacturing facilities and on regulations that adversely impact domestic manufacturers.”

PLASTICS submitted comments on March 31 based on member input, focusing on environmental and on occupational safety and health issues, and continues to seek additional recommendations for ways to streamline permitting and reduce regulatory burdens. Broadly, opportunities include: increasing information sharing within and between the Environmental Protection Agency (EPA) and States; eliminating/reducing overlapping or duplicative reporting; focusing on updates in permit renewal applications; streamlining Federal and State roles, and reducing the amount of wait time on Federal (and Federally-delegated State and Local) agencies to issue permits.

While support was noted for reconsiderations underway of the Clean Water Rule and the Risk Management Program (RMP) Rule amendments, focusing on priority actions was encouraged. Implementing policies, practices and procedures within existing permitting and regulatory frameworks are areas where reform measures could be accomplished with less resources than those needed to amend legislation, as with the recent amendment of the Toxic Substances Control Act (TSCA).

PLASTICS encouraged efforts to revise, reduce or eliminate those permitting and regulatory requirements that lack clarity, are outdated or are otherwise ineffective, and will continue to engage members and agency offices responsible for programs where opportunities for improvement are identified. For more information, please contact Marie Gargas.