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8/21/2013- Comments on EPA’s Formaldehyde Emissions Standards for Composite Wood Products and Third-Party Certification Framework for the Formaldehyde Standards for Composite Wood Products; Docket Nos. EPA-HQ-OPPT-2011-0380, EPA-HQ-OPPT-2012-0018.
Comment Letter Summary
Many small businesses operating in the composite wood products industry were anticipating the publication of the proposed rules, but most were unprepared for the extent to which the proposed rules exceed the California Air Resources Board's (CARB) Airborne Toxic Control Measure (ATCM) on Composite Wood Products. Small businesses believe that the proposed rules will impose greater burdens on them with out EPA having shown that the ATCM provisions are underperforming.
To reduce the burden on small businesses Advocacy urges EPA to follow the recommendations made by the Small Business Advocacy Review (SBREFA) Panel to the EPA Administrator, especially SBREFA panel's recommendation to "[a]dopt regulatory requirements that are consistent with the ATCM wherever possible." Adopting the SBREFA panel's recommendations will help reduce the burden on small businesses of complying with the proposed rules while ensuring the agency achieves its intended goals.