Advancing Industry Positions

Regulatory & Legislative Representation

As the voice of the flexible packaging industry, FPA works with regulators at the U.S. Environmental Protection Agency, the U.S. Occupational Safety and Health Administration, and other U.S. regulatory agencies such as the Federal Trade Commission and Food and Drug Administration to share industry positions and minimize the regulatory burden on the flexible packaging industry.

Food Safety Regulations

The Federal Drug Administration (FDA) is responsible for protecting the public health by assuring the safety and security of the nation's food supply, medical devices and drugs. The Flexible Packaging Association stays abreast of food safety legislation and changes affecting our member companies. Following are some of the resources currently available.

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Sustainability Marketing Claims – FTC Green Guides

The Federal Trade Commission issued revised Green Guides that are designed to help marketers ensure that the claims they make about the environmental attributes of their products are truthful and non-deceptive.

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Environmental Regulations

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Occupational Safety & Health Regulations

OSHA establishes mandatory job safety and health standards including guidance to reduce workplace hazards in order to protect American workers. Following are resources you may find helpful.

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The FPA Environmental, Health and Safety Program

The FPA Environmental, Health & Safety (EHS) Committee and the Environmental Issues Index form the basis for developing action plans to deal with regulatory issues that have potential to negatively impact the industry.  The committee is involved in a number of regulatory issues.

Toxic Substances Control Act (TSCA) Reform

Formally known as the Frank Lautenberg Chemical Safety for the 21st Century Act, HR 2576 was signed into law by President Obama on June 22, 2016. It authorizes EPA to regulate existing chemicals in commerce and reduces the agency’s burden to demonstrate that a chemical should be regulated because of its risk to the public and/or the environment. FPA successfully worked with an industry coalition to advocate for the exemption of mixtures and articles in the rule so that the...

Impact of EPA Removing Emergency Defense from Title V Permits

Because of a series of recent decisions by the U. S. Court of Appeals for the D.C. Circuit, EPA is requiring states to remove the “affirmative defense protections” against civil penalties from federal/state Title V Operating permit program during startup, shutdown and malfunction of equipment. The potential impact of this action on emission limitations during startup, shutdown and malfunction (SSM) of oxidizers in flexible packaging operations is under review.  Depending on the committee’s findings FPA may initiate a project to...

Printing and Other Web Coating MACT (POWC) Residual Risk

Under Section 112(f) of the Clean Air Act, the EPA is required to conduct risk and technology review (RTR) after 8 years of application of maximum achievable control technology (MACT) to determine if additional controls are required to provide an ample margin of safety to protect public health and the environment. The POWC MACT, with which many FPA members have to comply with, is currently undergoing EPA RTR review for Residual Risk determination. FPA continues to proactively work with EPA...

Solid and Hazardous Waste Regulatory Costs to FPA Members

EPA proposed and expects to finalize far reaching revisions to the hazardous waste generator management rules (RCRA Waste). Most FPA members are small quantity generators of RCRA regulated wastes, which are transported for offsite treatment except for solvents that can be recycled for cleaning presses. In December 2015, FPA submitted extensive comments on the proposed rule, particularly calling into question the reasonableness of requiring all small generators to retest every waste stream for possible coverage by the hazardous waste laws,...

OSHA’s Process Safety Management (PSM) Rulemaking

FPA has met several times with OSHA staff to discuss their views on what is likely to be included in the revisions to PSM Rule.  The amendments are required by President’s Executive Order 13650, “Improving Chemical Safety and Security.” Because of FPA’s interaction with OSHA on this issue and its relationship with the Small Business Administration (SBA Advocacy Group), one FPA member was invited to participate as a Small Employer Representative on OSHA’s Small Business Advocacy Review Panel. It allowed...

Global Occupational Health & Safety Management System (ISO 45001)

This Standard, aimed as a voluntary management system, is being developed by ISO’s Project Committee 283 (PC 283) which has a total of 78 countries participating including the U.S. Technical Advisory Group (U.S. TAG) composed of industry, OSHA, labor unions and NGOs. Since FPA is represented on U.S. TAG, it allows us to participate in U.S. TAG meetings and submit comments on drafted ISO 45001 documents. The standard as currently proposed is very prescriptive. The industry is working hard to...

OSHA adds Electronic Reporting to Injury & Illness Recordkeeping Regulations

Effective August 10, 2016 OSHA issued a final regulation that will require many employers to submit their Injury & Illness records electronically. Importantly, OSHA will then post the data from these submissions on its website available to public. The impact of this rule on affected employers is significant in that their customers, competitors, and the general public will have access to injury-Illness data which potential investors and customers may use to evaluate risk and liability without realizing that mere recording...