Fri Aug 28 15:21:40 EDT 2015

Leavy.Jacqueline@epamail.epa.gov

FW: NRDC/NEWMOA TSCA Petition for Rulemaking

To: CMS.OEX@epamail.epa.gov

_____________________________________________________________________________________________________

From: Susan Eastwood [mailto:seastwood@cleanwater.org]

Sent: Friday, August 28, 2015 3:12 PM

To: Mccarthy, Gina

Cc: Jones, Jim

Subject: NRDC/NEWMOA TSCA Petition for Rulemaking

Dear Administrator McCarthy,

Please accept the attached letter , signed by numerous Connecticut organizations representing thousands of CT citizens, in support of

the NRDC/NEWMOA TSCA Petition for Rulemaking on mercury.

Thank you,

Susan Eastwood

_____________________________________

Susan Eastwood

Director of Communications and Outreach

Coalition for a Safe and Healthy Connecticut

Clean Water Action

www.cleanwateraction.org

www.safehealthyct.org

2074 Park Street, Suite 308

Hartford, CT 06106

W: (860)232-6232; C: (860)428-5304

This message (including any attachments) is intended only for the use of the person(s) to whom it is addressed, and may contain information that is privileged, confidential, and exempt from disclosure

under applicable law. If you receive this message in error, please notify me immediately by email, telephone, or fax, and delete the original message from your records.

Thank you.
Phone 860-232-6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT

August 26, 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,

We, the undersigned, representing thousands of members and citizens across Connecticut who

care deeply about public health, wildlife and the environment, strongly urge your support of 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. These data will become the national mercury inventory that EPA

promised almost ten years ago.

Mercury, of course, is a powerful neurotoxin but EPA 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).

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,

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.

We urge EPA to grant the petition.

Sincerely,

Coalition for a Safe and Healthy CT

Connecticut Clean Water Action
Phone 860-232-6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT

Anne Hulick, CT State Director

Connecticut Citizen Action Group

Tom Swan, Executive Director

Connecticut Coalition for Environmental Justice

Sharon Lewis, Executive Director

Connecticut Nurses’ Association

Kimberly A. Sandor, MSN, FNP, RN, Executive Director

Connecticut Public Interest Research Group

Evan Preston, Executive Director

Citizens’ Campaign for the Environment

Louis Burch, Program Director

Ashford Clean Energy Task Force

 Susan Eastwood, Chair

 Janet Bellamy, Treasurer

ConnFact, (CT Families Against Chemical Trespass)

 Beth Beisel

 Tara Cook Littman

 Christine O'Day

New Haven Environmental Justice Network

Lynne Bonnett

Rivers Alliance of CT

Margaret Miner, Executive Director

Sierra Club Connecticut Chapter

John Calandrelli, State Program Director
Phone 860-232-6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT

The Watershed Partnership, Inc.

Jerry Silbert, M.D., Executive Director

Toxics Action Center

Sylvia Broude, Executive Director