The Alliance for Chemical Distribution (“ACD”) recently made a submission of comments to the United States Environmental Protection Agency (“EPA”) regarding the Advance Notice of Proposed Rulemaking (“ANPR”): Used Drum Management and Reconditioning 88 Fed. Reg. 54537 (August 11, 2023). As part of their comments, the ACD addressed the management of reconditioned and used drums.
The comments were submitted to the EPA by the ACD on November 17th, detailing their concerns with the proposed rulemaking. This development marks a key point in the ongoing dialogue between the chemical industry and environmental regulators, regarding the management and reconditioning of used drums.
Under the proposed rules, companies would be subject to new environmental standards and regulations, which may require adaptations of current practices. This, in turn, could impact supply chains, procurement strategies, and even end-use applications of chemical products.
By voicing their concerns, the ACD is ensuring that the practical implications and potential challenges associated with the rulemaking are taken into account by the EPA when finalizing these rules. It is a clear example of the critical role that industry bodies can play in shaping regulatory guidelines and policies.
For further details of the ACD’s comments and the specifics of the proposed rulemaking, find more information in the original article on JD Supra.