Position Statements

Request to EPA to reconsider the Container Rinsing and Recycling Rule Change (aka EPA "Container Rule") and Cost-Out the Impact of ACRC failure as the lead recycling group for small containers ≤ 55 Gallon HDPE: TPSA (2007)
This letter was sent to US EPA Administrator Stephen Johnson in response to EPA’s decision to release FIFRA 19 (h) aka “Container Rule” as an advance notice of proposed rules. The EPA's decision was made at a vulnerable time for the pesticide stewardship sector, the Ag Container Recycling Council (ACRC), and the thousands of farmers and agri-chemical dealers who want to do the right thing and triple rinse containers for recycling.

Pesticide Stewardship and “Cause-Related Marketing”: TPSA (2007)
This letter was sent to US EPA Administrator Stephen Johnson in support of TPSA concerns over EPA allowing Chlorox products to enter cause marketing by including a red cross on product labels. TPSA requested EPA reconsider their decision and assess concerns for stewardship issues with any cause marketing labeling.

Closing of EPA Regional Libraries: TPSA (2006) Letter
This letter was sent to US EPA Administrator Stephen Johnson in response to EPA closing several dozen regional EPA libraries to reduce operational costs. EPA is implementing a limited digital archiving plan; however, we believe that all holdings, whether EPA-generated or not, must be saved if they have significant scientific value. For those documents or holdings that do not fit within standards for digitization, an enhanced inter-library loan system must be developed so that valuable scientific information can remain available to interested parties. We call upon the EPA to cease library closings until a complete plan for document digitization and retention is implemented to assure public access to the historic record.

Pesticide Disposal Language Updates and New Challenges: NPSA letter (2004) to EPA regarding EPA Label Review Manual Revision
This letter supports the recommendations of the SFIREG Working Committee for Water Quality and Pesticide Disposal (WQ&PD); specifically, that pesticide product labels take a proactive approach and direct end users to recycling programs and away from open burning.