FPA – January February 2021 - 4

F PA N ews

WORKING THE RULES
FPA COMMITTEE MONITORS WORKPLACE REGULATIONS
BY DA N I D I E H L M A N N

FPA'S ENVIRONMENTAL, HEALTH, AND
SAFETY (EHS) Committee tracks regulatory developments on federal, environmental, and occupational safety
regulations and develops action plans to deal with those
that could impact the industry.
During the last six months, the committee weighed in
on several U.S. Environmental Protection Agency (EPA)
rulemakings that were deemed to affect members' facility
operations. It included support for the agency actions
designed to reduce regulatory red tape without compromising protections for public health and the environment.
Note that almost every move by the EPA to comply with
President Donald J. Trump's Executive Order 13777-
requiring federal agencies to " repeal, replace, or modify "
existing regulations to reduce the regulatory burden on
domestic manufacturers-has met fierce opposition by the
environmental community. Regardless of the of presidential election results, it is expected that challenges to these
EPA rules will dominate the federal courts in 2021.
Here's a look at highlights of some of the committee's
recent activities:
*	 " Once-in-Always-in " (OIAI) Policy: Based on a
policy document published in 1995, EPA maintained
4

F l e x P a c k V O I C E TM

FlexPackVOICE.com

that facilities that are a major source of Hazardous Air
Pollutants (HAPs) must permanently comply with the
applicable standard, even if the source subsequently
was no longer a major source of HAPs emissions. This
policy creates compliance burdens and does not reward
the HAPs reduction strategy. Over the years, FPA advocated for the repeal of this unsustainable policy without
success. Earlier this year, EPA proposed to reverse the
policy and FPA submitted lengthy comments in support
of the proposed rule, arguing that the 1995 policy
was inconsistent with the plain language of the Clean
Air Act and that it punished industries like flexible
packaging, which has eliminated most of the hazardous
materials from its manufacturing processes. The EPA
administrator signed the final rule on Oct. 1, and it will
be published shortly. This is a win for the industry and
FPA members, as it will allow many of them to now
become area sources, thus reducing compliance burden
and economic costs.
*	 Risk and Technology Review of Paper and
Other Web Coatings (POWC) MACT Rule: In
response to a consent decree entered with environmental groups, EPA proposed amendments to the


http://www.FlexPackVOICE.com

FPA – January February 2021

Table of Contents for the Digital Edition of FPA – January February 2021

FPA – January February 2021 - Cover1
FPA – January February 2021 - Cover2
FPA – January February 2021 - 1
FPA – January February 2021 - 2
FPA – January February 2021 - 3
FPA – January February 2021 - 4
FPA – January February 2021 - 5
FPA – January February 2021 - 6
FPA – January February 2021 - 7
FPA – January February 2021 - 8
FPA – January February 2021 - 9
FPA – January February 2021 - 10
FPA – January February 2021 - 11
FPA – January February 2021 - 12
FPA – January February 2021 - 13
FPA – January February 2021 - 14
FPA – January February 2021 - 15
FPA – January February 2021 - 16
FPA – January February 2021 - 17
FPA – January February 2021 - 18
FPA – January February 2021 - 19
FPA – January February 2021 - 20
FPA – January February 2021 - 21
FPA – January February 2021 - 22
FPA – January February 2021 - 23
FPA – January February 2021 - 24
FPA – January February 2021 - 25
FPA – January February 2021 - 26
FPA – January February 2021 - 27
FPA – January February 2021 - 28
FPA – January February 2021 - 29
FPA – January February 2021 - 30
FPA – January February 2021 - 31
FPA – January February 2021 - 32
FPA – January February 2021 - Cover3
FPA – January February 2021 - Cover4
https://www.nxtbook.com/ygsreprints/FPA/FPA_MarchApril2021
https://www.nxtbook.com/ygsreprints/FPA/FPA_JanuaryFebruary2021
https://www.nxtbook.com/ygsreprints/FPA/FPA_NovemberDecember2020
https://www.nxtbook.com/ygsreprints/FPA/FPA_SeptemberOctober2020
https://www.nxtbook.com/ygsreprints/FPA/FPA_JulyAugust2020
https://www.nxtbook.com/ygsreprints/FPA/FPA_MayJune2020
https://www.nxtbookmedia.com