Technological watch
ACC Statement on EPA Proposed Significant New Use Rules
WASHINGTON (Aug. 18, 2023) - The American Chemistry Council’s Plastics Division submitted comments to EPA regarding its proposing significant new use rules (SNURs) under the Toxic Substances Control Act. The following is a statement from Lee Salamone, Senior Director, Plastics Division of ACC:
“Pyrolysis-based advanced recycling is a critical part of the solution to a circular plastics economy. As written, the SNUR proposal would create an unworkable impediment that could hinder the advancement of innovative technologies to increase this circularity. ACC and our members remain eager to inform the EPA and other decision-makers about advanced recycling and clarify misconceptions being spread by its opponents and foster a more constructive path forward for this important manufacturing process.
“Progress towards a circular economy can only be achieved with smart, cohesive approaches that avoid inconsistent and conflicting approaches by regulators. To put it plainly, pyrolysis is not incineration. But it makes no sense and is counterproductive for one EPA office to explore the regulation of pyrolysis as incineration of solid waste while another office, EPA’s Office of Pollution Prevention and Toxics, considers pyrolysis to be chemical manufacturing under TSCA.
“Across its offices and programs, as multiple statutory programs and regulations are implemented, it is imperative that EPA have a consistent, cohesive approach to the materials and processes to be regulated. Anything less will add regulatory burden, cost and delays, and impede progress to a circular economy. EPA offices must find a path forward expeditiously to remove impediments and begin working together to achieve the Administration’s plastic pollution prevention policy goals.”
“Pyrolysis-based advanced recycling is a critical part of the solution to a circular plastics economy. As written, the SNUR proposal would create an unworkable impediment that could hinder the advancement of innovative technologies to increase this circularity. ACC and our members remain eager to inform the EPA and other decision-makers about advanced recycling and clarify misconceptions being spread by its opponents and foster a more constructive path forward for this important manufacturing process.
“Progress towards a circular economy can only be achieved with smart, cohesive approaches that avoid inconsistent and conflicting approaches by regulators. To put it plainly, pyrolysis is not incineration. But it makes no sense and is counterproductive for one EPA office to explore the regulation of pyrolysis as incineration of solid waste while another office, EPA’s Office of Pollution Prevention and Toxics, considers pyrolysis to be chemical manufacturing under TSCA.
“Across its offices and programs, as multiple statutory programs and regulations are implemented, it is imperative that EPA have a consistent, cohesive approach to the materials and processes to be regulated. Anything less will add regulatory burden, cost and delays, and impede progress to a circular economy. EPA offices must find a path forward expeditiously to remove impediments and begin working together to achieve the Administration’s plastic pollution prevention policy goals.”
This project has been co-funded with the support of the LIFE financial instrument of the European Union [LIFE17 ENV/ES/000438] Life programme
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