ACD Press Release

Arlington, VA –Today, National Association of Chemical Distributors (NACD) Senior Vice President of Regulatory Affairs Jennifer Gibson testified before the U.S. Environmental Protection Agency (EPA) at its virtual hearing on the Used Drum Management and Reconditioning Advance Notice of Proposed Rulemaking (ANPRM).

In her testimony, Gibson highlighted the chemical distribution industry’s use of drums and underscored the highest standards of safety that NACD members place on the transport of these used and reconditioned containers.

“Many NACD members and their customers generate used drums and transport them to reconditioners,” said Gibson. “They do so carefully, ensuring that they meet each of their regulatory obligations as they follow operating procedures required by Responsible Distribution®, and many also supplement these procedures with their own best practices.”

Gibson underlined NACD’s concerns that new, burdensome regulations will add significant strain on reconditioners and other stakeholders, while forcing more containers to be prematurely recycled or sent to landfills.

“NACD respectfully requests that the EPA reconsider many of the regulatory changes considered in this ANPRM. The current Resource Conservation and Recovery Act (RCRA) regulations have been highly effective in ensuring the safe and proper preparation, transport, and reconditioning, recycling, or disposal of used containers that held hazardous product. NACD fears that adopting new regulations that significantly alter the drum reconditioning industry would result in reconditioners closing their doors or significantly increasing their prices, causing fewer drums to be reconditioned and creating more waste and emissions. Instead, NACD urges the EPA to focus on improving its guidance and outreach to reconditioners, used drum generators, and transporters to better ensure that current regulations are followed.”

Gibson concluded, “By working together with the regulated entities to ensure they understand their obligations and by incorporating non-regulatory strategies such as performance-based standard operating procedures, the EPA can improve compliance with current regulations. This should be the EPA’s goal as the agency’s concerns outlined in this ANPRM occur when current regulations are not followed.”

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NACD and its over 400 member and Affiliate companies are vital to the chemical supply chain providing products to over 750,000 end users. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and a third party-verified management practice. For more information on NACD, visit www.nacd.com.