PMPA Comments on EPA's Proposed "Clarification" of TRI Article Exemption
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Monday, July 26, 2010 Bulletin Number: WP-18
We recently attended a meeting with OMB and EPA officials regarding
EPA's proposed "Clarification" of the Article exemption under TRI 313
Reporting. We were joined with representatives of roughly 14 other
industry spokespeople at this meeting.
Many precision machining shops make use of the article exemption in some
form, so any changes to the definition would require all precision
manufacturing companies to reassess their need to report under the new
clarification.
EPA's own estimates of reporting burden go to 51.3 hours to collect all
the needed data, evaluate your compliance to the rule, do the
calculations and report.
PMPA provided an analysis showing that the burden on just the precision
machining industry in the US would be of the order of $3.5 million,
fabricated metal industry, $66 million, and over $209 million for the
entire 33 NAICS code including precision machining, fabricated metal,
and machinery manufacture. Read More
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