Wed Sep 02 08:50:44 EDT 2015 Moritz.Brigette@epamail.epa.gov FW: Massachusetts organizations supporting NRDC/NEWMOA TSCA Petition for Rulemaking To: CMS.OEX@epamail.epa.gov

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From: Elizabeth Saunders [mailto:esaunders@cleanwater.org] Sent: Tuesday, September 01, 2015 6:01 PM To: Mccarthy, Gina Cc: Jones, Jim Subject: Massachusetts organizations supporting NRDC/NEWMOA TSCA Petition for Rulemaking

Dear Administrator McCarthy, Please find attached a letter from ten Massachusetts organizations supporting the NRDC/NEWMOA TSCA Petition for rulemaking on mercury added products filed on June 24th. Thank you for your consideration of this important petition. Sincerely, Elizabeth Saunders

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Elizabeth Saunders Massachusetts Director Clean Water Action

www.cleanwateraction.org/ma/ 88 Broad Street, Lower Level Boston, MA 02110
617-338-8131 x203 617-338-6449 fax

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**www.CleanWaterAction.org** August 24, 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,

Clean Water Action is a one million member organization of diverse people and groups joined together to protect our environment, health, economic well

- being and community quality of life. Our goals include clean, sa fe and affordable water; prevention of health threatening pollution; creation of environmentally safe jobs and businesses; and empowerment of people to make democracy work.

Clean Water Action strongly supports the June 24, 2015 petition of the Natural Reso urces Defense Council (NRDC) and the Northeast Waste Management Officials' Association (NEWMOA) to issue a rule requiring companies that import, produce, or use mercury (or mercury compounds) in manufacturing processes to provide data regarding these activ ities.

Mercury, of course, is a powerful neurotoxin with links to learning disabilities, autism and other serious health impacts. Despite the fact that these disorders and illnesses cost millions if not billions in health care, special education, and los t income costs, and significant improvements to human health and could be made from reducing use and release of this toxic chemical, EPA does not know how much is produced by the United States or imported each year, or how much is used and for what purpose s. NEWMOA gathers data on mercury use via the Interstate Mercury Education and Reduction Clearinghouse (IMERC) but this data is incomplete.

IMERC is limited in its product data collection by the reporting laws of the states that participate in this inte rstate collaboration. For this reason, IMERC does not currently collectdata on most switches and relays, even though this category was the largest use of mercury products for the last year that IMERC was collecting that data. IMERC lacks data on

mercury p roduction imports, or compounds used in industrial processes, as it focuses only on products. Other data gaps exist because of under

- reporting and non

- reporting.

Nearly ten years ago, EPA announced that it would create a national mercury inventory but
th at has yet to materialize, leaving a huge data gap that inhibits forward movement on this
front.

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, buildi ng 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.

For too long the US government has left mercury use data collection to the IMERC states. While these states’ reporting rules have been valuable and have resulted in t he collection of much useful data, this strategy is no longer fully effective. State based data collection needs to be complimented by a national reporting rule as requested by NRDC and NEWMOA.

Only with complete nationwide data will the US Government be able to fully protect its citizens and residents from this costly health threat and lead the way on implementation of this important international treaty.

Clean Water Action urges EPA to grant the petition.

Sincerely,

Robert Wendelgass
President & CEO