^ Minnesota .^y	.		Pollution Control Age ncy 

, . . 

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 to 

report 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, 

^ !

John Linc Stine 

Commissioner 

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