Regulations & EHS&S
SOCMA submits public comments on proposed TSCA User Fees 28th May 2018
The Society of Chemical Manufacturers & Affiliates (SOCMA) has submitted comments on the US Environmental Protection Agency’s proposed rule for user fees for the administration of the Toxic Substances Control Act (TSCA).
SOCMA is the only US-based trade association solely dedicated to the specialty and fine chemical industry. Its members play an indispensable role in the global chemical supply chain, providing specialty chemicals to companies in markets ranging from aerospace and electronics to pharmaceuticals and agriculture.
In its submission tot eh EPA, SOCMA says that it supports many aspects of the proposed rule, particularly:
- The alternative proposal to increase the PMN fee only by the rate of inflation
- Not charging fees for CBI claims
- Updating the small business threshold for inflation.
However, SOCMA says it has a number of concerns regarding the proposal, and believes it is critical that EPA make improvements to ensure that TSCA fee revenue is assessed in a manner that is fair and reasonable. SOCMA urges EPA to refines its approach on a number of points, including, for example:
- EPA should minimize fees for new chemical activities
- EPA should consider the impact of fees on innovation
- PMN eee should increase by no more than inflation
- EPA should not impose fees on Section 5 Exemption Applications.