Wed Sep 02 16:18:29 EDT 2015 Labbe.Ken@epamail.epa.gov FW: Letter from 22 groups in support of NRDC/NEWMOA petition To: CMS.OEX@epamail.epa.gov

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From: Elizabeth Saunders [mailto:esaunders@cleanwater.org] Sent: Wednesday, September 02, 2015 2:20 PM
To: Mccarthy, Gina Cc: Jones, Jim Subject: Letter from 22 groups in support of NRDC/NEWMOA petition

Dear Administrator McCarthy, Please find attached a letter signed by 22 groups from across the country in support of the June 24th petition by NRDC and NEWMOA to require mercury-product notification.

Thank you for your attention to this important issue.

Best, Elizabeth Saunders Multi-state Mercury Products Campaign Coordinator

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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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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.September 2, 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,

The 22 undersigned organ izations work to address public health and environmental concerns of communities across the United States. We are very concerned with the impacts of mercury pollution on human health, wildlife and the environment.

We are writing to you today to support the petition filed by the Natural Resources Defense Council (NRDC) and the Northeast Waste Management Officials' Association (NEWMOA) on June 24, 2015 to issue a rule requiring companies which import, produce, or use mercury (or mercury compounds)
in manuf acturing processes to provide data regarding these activities. A national mercury inventory was promised by EPA nearly a decade ago and these data are necessary to fulfill that promise.

Despite the fact that mercury is a powerful neurotoxin linked to signi ficant environmental and public health damage, the US is in the dark about how much is used or imported in the country and by what industries. While NEWMOA compiles data in the Interstate Mercury Education and Reduction Clearinghouse (I MERC), this databas e is lacking information on mercury production or imports as well as on mercury compounds manufactured or imported for use in industrial process es. Furthermore, the largest product category of mercury use in products as of 2010 was switches and relays, an d IMERC no longer includes current data on this product category because all of the states that require reporting to IMERC of mercury product sales have ended sale of mercury switches and relays. IMERC’s data is also incomplete due to underreporting and n on

- reporting.

The petition seeks a rule under the Toxic Substances Control Act which will fill these gaps and produce missing data on product categories, such as children’s products. It will build on data now collected by the State of Washington. The ru le would provide the US government with the data

needed to meet its obligations under the Minamata Convention to phase

- down mercury use in multiple categories and discourage new uses of mercury.

For too long, mercury use data collection has been left to st ates. It is time that this activity be coordinated by EPA, building on and complimenting current IMERC data collection for maximum efficiency and effectiveness.

We urge EPA to grant the petition.

Sincerely,

Pamela Miller, Executive Director
**Alaska Communi ty Action on Toxics**  Anchorage, AK Bill Magavern

, Policy Director
**Coalition for Clean Air** Sacramento & Los Angeles, CARonald White

, Director of Regulatory Policy
**Center for Effective Government** Washington, DC

Mike Belliveau, Executive Director
**Environmen tal Health Strategy Center**  Portland, Maine

Daniel Parshley, Project Manager **Glynn Environmental Coalition** Brunswick, GA

Arlene Blum, Executive Director **Green Science Policy Institute** Berkeley, CA

Eric Uram
**Headwater LLC** Madison, WI

Rachel L. Gibson, JD, MPP, Director, Safer
Chemicals
**Hea lth Care Without Harm** 
US and Canada

Bill Walsh

, Executive Director **Healthy Building Network** Washington, DC

Deanna White & Kathleen Schuler, Co

Directors **Healthy Legacy Coalition** Minneapolis, MN

Dr. Olga Speranskaya and Manny Calonzo,
Co

- Chairs

**IPEN**

Ber keley, CA & Sweden

Michael Bender, Director **Mercury Policy Project** Montpelier, VT Pete Didisheim, Senior Director of Advocacy
**Natural Resources Council of Maine** Augu sta, ME

Niaz Dorry

, Coordinating Director
**Northwest Atlantic Marine Alliance** Gloucester, MA

Melanie Houston

, Director of Environmental
Health
**Ohio Environmental Council** Columbus, OH

Chris Hagerbaumer, Deputy Director **Oregon Environmental Council** Portland, OR

Sejal Choksi

- Chugh, Executive Director & Baykeeper **San Francisco Baykeeper** Oakland, CA

Charlie Winterwood

, Chair
**Sierra Club**

**- National Toxics Committee**  San Francisco, CA

Ro bin Schneider

, Executive Director **Texas Campaign for the Environment**

Austin

, TX

Matt Prindiville, Executive Director **UpStream** Rockland, ME

Paul Burns, Executive Director **Vermont Public Interest Research Group** Montpelier, VT

Yolanda Whyte,MD, President **Dr. Whyte Pediatrics** Atlanta, GA