Wed Sep 02 08:50:24 EDT 2015

Moritz.Brigette@epamail.epa.gov

FW: Clean Wisconsin support for NRDC/NEWMOA TSCA mercury petition

To: CMS.OEX@epamail.epa.gov

_____________________________________________________________________________________________________

From: Amber Meyer Smith [mailto:asmith@cleanwisconsin.org]

Sent: Tuesday, September 01, 2015 6:10 PM

To: Mccarthy, Gina

Subject: Clean Wisconsin support for NRDC/NEWMOA TSCA mercury petition

Attached please find a letter of support from Clean Wisconsin for the NRDC/NEWMOA TSCA petition for rulemaking. Thank you for

your consideration.

Amber Meyer Smith

Director of Programs and Government Relations

Clean Wisconsin

634 W. Main St, Suite 300

Madison, WI 53703

(608) 251-7020 ext. 16

asmith@cleanwisconsin.org
634 W. Main Street #300, Madison, WI 53703

608-251-7020 | www.cleanwisconsin.org

September 1, 2015

Gina McCarthy, Administrator (Mail Code 1101A)

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Re: NRDC/NEWMOA TSCA Petition for Rulemaking

Dear Administrator McCarthy,

I write on behalf of Clean Wisconsin’s 30,000 members and supporters to support the June 24, 

2015 petition of the Natural Resources Defense Council (NRDC) and the Northeast Waste 

Management Officials' Association (NEWMOA) to issue a rule requiring companies which 

import, produce, or use mercury (or mercury compounds) in manufacturing processes to 

provide data regarding these activities. Collection of this data is important to establish the 

national mercury inventory that EPA promised almost ten years ago. 

Clean Wisconsin has been working for years to prevent mercury from polluting our 

environment. We continue to advocate for state-level policies that advance protections from 

toxic mercury.

But those advancements are difficult when EPA still does not know how much is produced by 

the United States or imported each year, or how much is used and for what purposes. The only 

significant data on mercury use are currently compiled by NEWMOA, which manages the 

Interstate Mercury Education and Reduction Clearinghouse (IMERC).While that data is valuable 

it leaves us without a complete picture of mercury use in all states.

IMERC targets only mercury use in products, and thus does not collect data on mercury 

production or imports; or mercury compounds manufactured or imported for use in industrial 

processes. Moreover, IMERC is no longer collecting data on most switches and relays, the 

largest mercury use in products, and its program contains other significant data gaps due to 

underreporting and non-reporting. 

The TSCA rule sought by the petition will fill these gaps, and produce needed information on 

questionable mercury uses, such as in children's products, building upon the data now collected 

by the State of Washington. And it will collect the data needed to inform US Government action 

under the Minamata Convention to phase-down mercury use in polyurethane manufacturing, 
634 W. Main Street #300, Madison, WI 53703

608-251-7020 | www.cleanwisconsin.org

identify large mercury stocks in storage or annually produced, and discourage new mercury 

uses in products or industrial processes. 

Until now, most mercury use data collection and regulatory activity has been undertaken by the 

IMERC states. The reporting rule requested by NRDC and NEWMOA is designed to coordinate 

with and complement the IMERC activities, and will therefore be both efficient and effective.

Clean Wisconsin urges EPA to grant the petition.

Sincerely,

Amber Meyer Smith

Director of Programs and Government Relations

Clean Wisconsin