The CSB proposed rules impose on industry, including printing operations, new accidental chemical release reporting requirements in addition to existing reporting requirements under several EPA regulations. The proposed rule is confusing in that it utilizes different definitions than used under other EPA release reporting rules and requires facilities to undertake a new analysis of the type of chemical release that would fall under the scope of the CSB’s reporting requirements.
The comments submitted objected to the very low threshold required to report chemical releases. The comments also pointed out the economic impact assessment grossly underestimated the costs associated with this new reporting requirement and the erroneous assumption made by the CSB that small businesses would not be required to report under the new rule. Many SGIA members would have to report under this regulation, while they would not have to necessarily report a release to EPA. The comments requested the CSB to align their requirements with those currently established by EPA.
SGIA attended a Small Business Administration rule on Friday January 24, 2020 and the CSB proposal was a topic that received a lot of attention and discussion. A presentation on the requirements was given by a law firm, Con Maciel Carey LLP. On behalf of an Industry Coalition, they also submitted comments opposing the proposed rule. Their main concern stems from the fact that this proposed rule is redundant with existing reporting requirements established by other regulatory agencies. The CSB is already receiving all of the information the new Accidental Release Reporting Rule would provide. One of the key points in the comments submitted by Con Maciel Carey stated that it is unnecessary to allocate scarce CSB resources toward sorting through duplicate information.
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