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Eisenberg, Ross [Ross_Eisenberg@americanchemistry.com] 3/30/2020 2:39:32 PM Gunasekara, Mandy [gunasekara.Mandy@epa.gov] ACC statement on EPA enforcement discretion ATT00001.txt
This went out from the CEO. Happy to answer questions anytime.
https://blog.americanchemistry.com/2020/03/epas-temporary-enforcement-discretion-policy-provides-importantflexibility-to-manufacturers/
EPA's Temporary Enforcement Discretion Poli,y Proviclos Important Flexibility to Manufacture's
by Chris Jahn I March 28, 2020
U.S. Environmental Protection (EPA)'s decision to grant
.4r1forr.Rmpr,+ clisnrAtir+ will
provide manufacturers with additional time to complete administrative requirements such as
regulatory filings and allow inspections to be rescheduled after workforce shortages, travel and
movement restrictions no longer present uncontrollable challenges to compliance.
2024-EPA-05254
Sierra Club FOIA 2024-EPA-05254
ED_017426_00003189-00001
SC_EVERSPLIT0002400
This
t qrm mansr- is needed because essential personnel and resources must be devoted to
maintaining production and meeting increased demand for
pluducLb such as
sanitizers,
, and plastics for consumers, governments and the health care community.
While some manufacturing plant personnel have been Askinat as eSSAnti' l to allow for continued operations, the vast majority of other company employees are subject to telework requirements, travel restrictions and stay-at-home orders consistent with Centers for Disease Control and Prevention ( ) and local or state government requirements. Because of this, many administrative activities such as regulatory filings and inspections simply may not feasible during this period.
The principle of providing flexibility in meeting regulatory requirements goes back decades and was
invoked in the aftermath of Hurricane Katrina, an event equally as unique and unprecedented as what
the United States faces today from _
. Any company in need of this flexibility will be required
to fully document and submit to EPA a rationale and plan to resolve any outstanding regulatory
requirements.
All ACC members are committed to safe and responsible operations, and agree that enforcement discretion should only be sought when absolutely necessary. We, like all other Americans, look forward to the time when the risk to our employees and communities has passed and such flexibility and discretion will no longer be needed.
Ross Eisenberg I American Chemistry Council Vice President, Federal Affairs Ross_Eisenberg@americanchemistry.com 700 2nd Street, NE I Washington, DC I 20002 0: (202) 249-6200 M: (703) 517-1655 www.americanchemistry.com
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2024-EPA-05254
Sierra Club FOIA 2024-EPA-05254
ED_017426_00003189-00002
SC_EVERSPLIT0002401