Advocacy

ASC members work together through the ASC to advocate for industry growth, policy development, and reasonable and balanced regulation. To ensure stakeholders understand our industry's underlying value premise, ASC proactively communicates industry messaging in a collaborative, member-driven manner.
Our three strategic advocacy objectives are
  1. Collaborate with adjacent and industry groups to advance shared advocacy initiatives.
  2. Engage with government agencies and regulatory groups to improve visibility and establish a pulse on emerging threats.
  3. Establish strategic partnerships with NGOs and consumer advocacy groups to provide access to and engage secondary audiences.

ASC's Regulatory Advocacy Focus

Adhesives and sealants are regulated at the federal, state, and local levels through a variety of government rules and regulations. Though most of our focus is on federal regulations, states such as California actively regulate adhesives and sealants at the state and regional level and require our engagement.
Federal
ASC engages most frequently with the U.S. Environmental Protection Agency (EPA). U.S. EPA's Toxic Substances Control Act (TSCA) regulates chemicals in commerce, including raw materials used in adhesive manufacturing. Recent comments, position papers, or coalition letters listed below.

ASC Comments on EPA's Proposed Risk Management Rule under TSCA Section 6(a) for n-methylpyrrolidone (NMP) (July 2024)

ASC Comments on EPA's Proposed Risk Evaluation for Formaldehyde in adhesive and sealant processing, industrial, and consumer uses (May 2024)

ASC Comments on EPA's Proposed Rule imposing prohibitions on trichloroethylene in adhesive and sealant commercial and consumer uses (December 2023)

ASC Comments on EPA's Proposed Rule on procedures for risk evaluation under the Toxic Substances Control Act (December 2023)

ASC Comments on EPA's Proposed Rule imposing bans and restrictions on the use of carbon tetrachloride in adhesives and sealants for many industrial and consumer uses (September 2023)

ASC Comments on EPA's Proposed Rule aligning TSCA's New Chemicals regulations with the Frank R. Lautenberg Chemical Safety for the 21st Century Act amendments (August 2023) 

ASC Comments on EPA's Proposed Rule imposing bans and restrictions on the use of methylene chloride in adhesives and sealants for many industrial and consumer uses (June 2023)

State

ASC engages states to better educate them on the benefits that adhesives and sealants deliver to everyday living. We also engage when state agencies propose rules and regulations that impact the manufacture, sale or distribution of our industry's products, such as California's Proposition 65 or those that unnecessarily ban or restrict the manufacture of adhesive and sealant products. Recent comments, position papers, or coalition letters listed below.

ASC letter opposing the California Office of Environmental Health Hazard Assessment (OEHHA) decisions to modify the Proposition 65 short form warning label (June 2024) 

ASC joins coalition letter opposing the California Office of Environmental Health Hazard Assessment (OEHHA) decisions to modify the Proposition 65 short form warning label (June 2024)

ASC joins coalition letter opposing legislation that would create an overly broad and complex new regulatory program at California's Department of Toxic Substances Control (DTSC) to regulate all commercial and consumer products, as well as any industrial manufacturing process that may use, PFAS substances (March 2024)

ASC joins coalition letter opposing sweeping legislation banning essential consumer products containing PFAS (January 2024)

ASC joins coalition letter opposing proposed amendments to OEHHA's Proposition 65 short form warning label (January 2024)

ASC joins coalition letter opposing Maine legislation imposing a comprehensive ban on critical uses containing PFAS (June 2023) 

ASC letter to California's Office of Environmental Health Hazard Assessment (OEHHA) commenting on second modifications to proposed amendments to short form Proposition 65 warning (April 2022)

ASC letter to California's Office of Environmental Health Hazard Assessment (OEHHA) commenting on modifications to proposed amendments to short form Proposition 65 warning (January 2022)

ASC letter to California's Office of Environmental Health Hazard Assessment (OEHHA) commenting on the Notice of Intent to list 2-ethylhexyl acrylate (2-EHA) on Proposition 65 (July 2021)

ASC letter to California's Office of Environmental Health Hazard Assessment (OEHHA) commenting on proposed amendments to short form Proposition 65 warning (March 2021)

Local/Regional
ASC engages regulators at the local and regional level when necessary, such as California's South Coast Air Quality Management District (SCAQMD), which regulates emissions of volatile organic compounds (VOCs). Recent comments or position papers listed below.

ASC letter to the South Coast Air Quality Management District (SCAQMD) regarding proposed updates to Rule 1168 re: adhesive and sealant VOC regulation (April 2021)


ASC Regulatory Affairs Committee

Priorities and activities are directed by ASC's Regulatory Affairs Committee (RAC). The Committee meets quarterly and as necessary in between to discuss regulatory developments and identify opportunities to collaborate and engage with regulators and allied associations.
Members can request past Committee meeting presentations by contacting ASC.
Members can volunteer to serve on the RAC by contacting ASC. We welcome your participation!


ASC Member Resources

Monthly Regulatory Newsletter (members-only)

Each month ASC members receive a free newsletter via e-mail that summarizes important regulatory policy developments. The newsletter is produced each month by Thompson Hine LLP.
If your company is an ASC member and you would like to receive a copy emailed to you each month, please contact ASC.


PFAS In Products State Law Tracker

Hunton Andrews Kurth LLP has developed a public, searchable tracking tool that tracks state statues and regulations that ban or impose reporting or disclosure requirements for products containing PFAS. You can search by state, type of product, compliance date, and type of regulation.

Click the image to view