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

_____________________________________________________________________________________________________

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

--

***************

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

***************

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.
1444 Eye St, NW, Suite 400, Washginton, DC 20005

Phone (202) 895-0420 | cwa@cleanwater.org

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, safe 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 Resources 

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 activities. 

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 lost 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 purposes. 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 interstate collaboration. For this reason, IMERC does not currently collect 
data 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 production 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 

that 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, 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. 

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 the 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