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520 Lafayette Road North I St. Paul, Minnesota 55155-4194 1 651-296-6300 800 657-3864 1 651 282-5332 TTY I www.pca.state.mn.us j Equal Opportunity Employer 

### August 14, 2015 

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7015.A'lJG 214 P11 2 : 43 

### Gina McCarthy, Administrator United States Environmental Protection Agency 

### Mail Code 1101A 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Jim Jones, Assistant Administrator Office of Chemical Safety and Pollution:Prevention United States Environmental Protection Agency Mail Code 7101M 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Re: NRDC/NEWMOA TSCA Section 21 Citizens Petition for TSCA Section 8(a) Rulemaking for Mercury Reporting Dear Administrator McCarthy and Assistant Administrator Jones: The Minnesota Pollution Control Agency (MPCA) has a long-standing interest in reducing the use 

### and release of inercury and mercury compounds. We are writing in support of the June 24, 2015, TSCA Section 21 Citizens Petition from co-petitioners Natural Resources Defense Council (NRDC) and Northeast Waste Management Officials' Association (NEWMOA) asking U.S. EPA to issue TSCA Section 8(a) rules requiring companies which import, export, produce, or use mercury (or mercury compounds) in products and manufacturing processes to provide data regarding these activities. This data will become the national mercury inventory that EPA promised almost ten years ago. Mercury 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 is currently compiled by NEWMOA, which manages the Interstate Mercury Education and Reduction Clearinghouse (IMERC). IMERC targets only mercury use in products, so it does not collect data on mercury production or imports, or data on production or import of inercury compounds used in industrial processes. Moreover, IMERC is no longer collecting data on most switches and relays, the largest mercury use in products, since sales of most products are now prohibited in states that require manufacturers toreport to IMERC. In addition, there are other significant data gaps due to underreporting and nonreporting by manufacturers. The TSCA reporting 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. It will collect the data needed to inform U.S. Government action under the Minamata Convention to phase-down mercury use in products and industrial processes such as polyurethane manufacturing, identify large mercury stocks in storage or annually produced, and discourage or prohibit new mercury uses in products or industrial processes.G. McCarthy and J. Jones

Page Two August 14, 2015



### Until now, most mercury use data collection and regulatory activity have 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. The MPCA has been a member of IMERC since 2004. The MPCA strongly urges U.S. EPA to grant the NRDC/NEWMOA TSCA Section 21 Citizens Petition and issue proposed and final TSCA Section 8(a) mercury reporting rules on an expedited schedule. Sincerely, 

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John Linc Stine Commissioner KK:JG:cmbg^ li ' ci 0m W Z o ^ ^I °Q LU 0 I bR co 

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