Too Many Regulations?

There's no telling what it will cause, besides making everything more expensive and possibly driving manufacturers out of business.

Where is the data showing that coatings manufactures are fouling the air and water supplies?

Where is the data to show that these new rules are justified?

The EPA needs to be dismantled and stripped down to a manageable agency with strict and limited powers.

Manufacturers that are found to be dumping toxic waste into the ground should be fined out of existence and permanently shut down.

The ACA supports the rules , but asks that the process be streamlined

these rules are to prevent the companies from using paperwork to do slight of hand recycling

I would be interested in ACA's counterproposal

the new rules were in reaction to a lawsuit from the sierra club

are you really suggesting that there is no data showing a negative environmental impact from the manufacture of paint & other coatings?

the below statement makes it clear that ACA, would like to be able to recycle without any supervision, what could possibly go wrong?

Finally, ACA opposes making all the legitimacy criteria mandatory and opposes requiring recyclers to provide documentation demonstrating how they meet the legitimacy requirements. ACA strongly believes that adding new requirements and provisions to the pre-2008 exclusions and exemptions is not appropriate for this rulemaking and would have far-reaching, unintended consequences.

Every human activity has an environmental impact.

I would like to see the data that shows that coatings manufacturers are poisoning ground water, ecosystems, etc., and how exactly more rules are going to stop it.

The EPA has become a dangerous runaway train. I suspect that the new rules that are being added to the old rules are based on a skewed notion of what's right and wrong, and hypothetical conjecture....................not reality.

Everything that comes down the pike these days is based on the assumption that every industry, business, etc., and the people that work for them, are inherently evil, out to screw others over, and destroy the planet.

I would also be interested in knowing what the game plan is for the post industrial era that we're entering as these bastards punish and shut down one US business after another.

Like I've said before, we need some reasonable rules and regulations, and they should have teeth. Companies that are caught intentionally polluting rivers, streams or ground water should be punished right out of existence. Other than that, the government needs to stay the hell out of the way. There is no way they will ever be able to afford to put us all on food stamps, welfare, and Medicaid.

Maybe the government should just take over the coatings industry and hire $50 per hour union workers to hand grind all ingredients by mortar and pestle.

that's absurd

you are really suggesting that the solvents & dies are harmless?

& that there isn't nearly endless amount of data about the environmental impact?

of course the industry doesn't think there should be any regulations whatsoever, we've already tried that

responsibility took a back seat to profit & the resources held in common [air/water] were abused

the regulation/reaction may very well have gone too far, the answer is not to leave industry to their own devices...

it's going to take work to figure out what makes sense & it is going to change over time

these are proposed rules, not the final

be involved in the process [make a comment to the EPA] instead of calling for the abolishion of regulation, because the process is hard [& necessary] work

Nope, I never suggested that solvents and dyes are harmless.

I am suggesting that it doesn't require mountains of regulations and rules to keep toxic chemicals out of the water supply. All it would require is a relatively small set of rules to insure the proper handling of toxic stuff. If companies decide to roll the dice and get sloppy with it, and get caught...................they are finished, kaput, shut down.

The EPA is just one more government agency that has grown too fat and dangerous. It's time to cut them down to size..................along with almost every other department and agency.

I can write letters to the EPA all day long. It won't do any good. They have become more powerful than congress.

apparently it does require mountains of paperwork to make the manufacturers act responsibly

look at the ACA statement from #2 they want us to take their word that hey are recycling within their [members] plants properly.

I'm not seeing ACA saying we already have adequate systems in place, lets use ours documentation instead...

the public comments do matter, the bureaucrats do respond to public pressure

certainly more likely improve the situation than

wringing our hands & complaining about how terrible the government is & waiting for someone else to fix it

the TP er's aren't going to clean it up

not enough support

EPA proposed revisions to the 2008 DSW final rule in response to EPA's settlement agreement with Sierra Club from a lawsuit in 2010.

Sounds to me like we've got the Sierra Club crafting new regulations.........Not good.

or determined by EPA or an authorized state to be non-wastes on a case-by-case basis, via a petition process.

Yep. Mountains of paperwork.

This change is a response to EPA's determination that the 2008 DSW final rule had "serious gaps" which created the potential for adverse effects on human health and the environment from discarded wastes.

Just as I suspected. The coatings manufacturers have done nothing wrong to warrant more rules. There is just a potential.

The proposal requires recyclers to meet certain conditions before qualifying for the exclusion and lists 18 designated solvents that will fall under this new exclusion.

More paperwork, just to have 18 solvents excluded from the new rules. If I was a coatings manufacturer, I'd be looking at potential plant locations in Mexico.

Sierra Club found a hole in the documentation process

sued to make EPA figure it out

mind you ACA could have taken the initiative & fixed the system themselves

so EPA has to get involved

a comprehensive cradle to grave tracking system is probably less paperwork than the clusterfuqk of recordkeeping going on now

why should any solvents be excluded?

I like my water solvent free thanks

moving out of the country is a cop out, they make their money here, be part of the solution.

anyway won't the hotdogs get cold?

As usual, it's impossible to tell what's really going on here. It doesn't sound like the coatings manufacturers did anything wrong.

If the entire thing is going to result in the exclusion of 18 solvents, then yes, it seems to me to be a monumental waste of time and money, that will actually change very little, if anything.

I do remember when Att/Bell was the only game in town. Long distance was expensive, but they were the only ones to spend any money on the infrastructure to deliver it. The option would have been, no long distance calls. Even if there had been competition, long distance calling still would have been expensive back then, due to the technology that was being used. Besides, hasn't AT&T morphed right back into a single conglomerate?

when it come to toxins the bar does continue to be raised & rightfully so

how can responsible behavior be encouraged?

the carrot is cheaper than the stick

better to never have the government react to transgressions, by incentivizing self regulation

Companies that are found to be intentionally dumping toxic chemicals in the ground, rivers, etc., should be shut down, and the people behind it get to go to prison. That's what I mean when I say that we should have reasonable regulations...................they need to have real teeth too. If the punishment for getting caught is stiff enough, nobody in their right mind is going to give the order to intentionally pollute.

define intentional

if there are no records how would anyone know?

wouldn't that lead to even more short term thinking?

define reasonable regulations?

doing things the right way costs more money...

that can easily be construed as unreasonable, by a bean counter or executive who's bonus will be negatively impacted

the VA & secret police Homeland security aren't the EPA, now are they?

you would like to believe businesses will do the right thing, even if it costs them more money...

it would be great to live in that place

locks are to keep the honest people honest [I agree we have too many locks {requlations} & they all seem to take a different key]. this stuff needs to be integrated, within the MRP [materials resource planning] systems & not as an independent systems. this is the point when I'm blathering on about [other threads] how the massive changes in information technology, haven't been utilized by our social organizations.... after all the paint guys need to keep track of what they are using & where it's going, just good business. Recycling solvents within the manufacturing process, good business [long term]. The record keeping doesn't have to cost more, generally the most expensive part is getting the data into & out of the system.

we could have a whole different discussion(s) about the expanding homeland security budget, much of which has little to no oversite

or the VA, which can't keep up with aftercare for all the broken people [mentally & physically] created, from adventures in "democracy" Iraq & Afganistan editions