FPA Signs a Coalition Letter on EPA’s Proposed TSCA 8(a)(7) Reporting and Recordkeeping Rule and the Associated IRFA

The undersigned organizations are pleased to provide comments regarding the Initial Regulatory Flexibility Analysis and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule. In our extension request, we underscored our appreciation for EPA’s work with regard to assessing the costs of the proposal for small businesses across the U.S. Convening the Small Business Regulatory Enforcement Fairness Act panel rightly identified these and other challenges and also recognized significant additional impacts of the proposed rule. The revised analysis, however, still does not comply with EPA’s obligations under the Executive Orders for regulatory review, the Regulatory Flexibility Act, and the Paperwork Reduction Act (PRA).