Industries Need To Challenge EPA’s Decision To Disregard Statutorily Required Exemptions
Numerous industries – including electronics, textiles, plastics, and even golf balls – have until October 28, 2019, to file comments challenging a fundamental legal flaw with the U.S. Environmental Protection Agency’s (EPA) precedent-setting proposed rule concerning certain persistent, bioaccumulative, and toxic (PBT) chemicals: the failure of EPA to apply the statutory exemptions for articles and replacement parts as required by section 6(c)(2) of the Toxic Substances Control Act (TSCA).1