Two issues were on top of the agenda at the July meeting of FPA’s Environmental, Health & Safety Committee (EHS). They were changes to the Toxic Substances Control Act (TSCA) and OSHA’s upcoming revision of the Process Safety Management (PSM) Rules.

EPA gained added authority under TSCA reforms signed into law and is now able to regulate existing chemicals in commerce. Next year, EPA has to prioritize chemicals. It also has to set a fee schedule and publish a risk assessment rule. Expect EPA to regulate chemicals including “nano-forms” of existing compounds if it finds potential exposure to a chemical.

OSHA continues to collect information as it gets ready to propose revisions to the PSM rule, required under an Executive Order, to improve chemical safety and security in the U.S. The major impact on the flexible packaging industry is OSHA’s proposal to bring atmospheric storage tanks under PSM. As a small business representative on OSHA’s Small Business Advocacy Review Panel, FPA submitted written comments and expects to offer wider input when the rule is proposed.

The committee also addressed the following issues at the July meeting:

  • EPA amendments on air pollution requirements for site remediation.
  • Litigation that would define “solid waste” to affect recycling of solvents.
  • Communication with EPA on the Paper & Other Web Coating MACT Residual Risk Analysis.
  • Analysis of ISO 45001 draft comments.

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Contact Ram Singhal at 410-694-0823 or at