Skip to main content
Stay Connected
Facebook
Twitter
LinkedIn
Sign in
Cart
Contact Us
Create Account
Toggle navigation
ILMA Submits Comments On EPA’s TSCA User Fee Proposed Rule
April 24, 2018
ILMA last week
submitted comments
regarding EPA’s Toxic Substances Control Act (TSCA) User Fee proposed rule.
The June 2016 TSCA amendments authorize EPA to promulgate a user fee collection rule for payments from chemical manufacturers, importers, and processors to defray the Agency’s costs to administer the revised statute.
EPA is authorized to collect through user fees 25 percent of the costs associated with implementing the amendments, which the Agency approximates to be $80.2 million.
In its comments, ILMA noted that the proposed fee schedule for “large businesses” is too high and appears largely inconsistent with actual time and effort it would take to complete particular TSCA activities.
ILMA also noted that it was both appropriate and overdue for the Agency to increase the size standards and the associated fee schedule for small entities; however, ILMA proposed a reduced fee schedule to ensure that small businesses can remain competitive.
Finally, ILMA pointed out that issues may arise in a scenario in which both small and large companies form a consortium for testing, as an example, and that it could result in the unintended consequence of forcing a small company to pay “large” company fees. The Association encouraged EPA to clarify how it will handle such as situation.
The original comment deadline was April 27; however, EPA
just announced
it will extend the deadline for an additional 30 days.
{1}
##LOC[OK]##
{1}
##LOC[OK]##
##LOC[Cancel]##
{1}
##LOC[OK]##
##LOC[Cancel]##