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

_____________________________________________________________________________________________________

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

--

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

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.
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 organizations 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 manufacturing 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 significant 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 (IMERC), this database is lacking information on mercury production or imports as 

well as on mercury compounds manufactured or imported for use in industrial processes. 

Furthermore, the largest product category of mercury use in products as of 2010 was switches and 

relays, and 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 non-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 rule 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 states. 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 Community Action on Toxics

Anchorage, AK

Bill Magavern, Policy Director

Coalition for Clean Air

Sacramento & Los Angeles, CA
Ronald White, Director of Regulatory Policy

Center for Effective Government

Washington, DC

Mike Belliveau, Executive Director 

Environmental 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

Health Care Without Harm

US and Canada

Bill Walsh, Executive Director

Healthy Building Network

Washington, DC

Deanna White & Kathleen Schuler, CoDirectors 

Healthy Legacy Coalition

Minneapolis, MN

Dr. Olga Speranskaya and Manny Calonzo, 

Co-Chairs

IPEN

Berkeley, CA & Sweden

Michael Bender, Director

Mercury Policy Project

Montpelier, VT

Pete Didisheim, Senior Director of Advocacy

Natural Resources Council of Maine

Augusta, 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

Robin 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