Many complain about the regulatory burden plastics manufacturers, especially small and medium plastics processors, must bear. But what if there was a way to get in front of the process, to make yourself heard by the rulemakers and regulators before they start writing? From time to time there are such opportunities. Small to medium manufacturers are asked to give input to the Occupational Safety and Health Administration and the Environmental Protection Agency when they are thinking about a new regulation or revising an existing one that could affect such companies. It's the law.
The Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996 was passed to enable small businesses to participate in and have access to federal regulators. Under SBREFA, covered agencies — EPA, OSHA and the Consumer Financial Protection Bureau — must conduct a Small Business Advocacy Review (SBAR) panel before publishing a proposed rule. This SBAR panel — a chair from the agency, the chief counsel for the Office of Advocacy, and the administrator of the Office of Information and Regulatory Affairs — meets with representatives of directly regulated small entities, giving them a way to provide advice and recommendations on regulatory alternatives to minimize the burden on small entities.
If you're interested, the Society of the Plastics Industry can make the connection. SPI maintains close contact with EPA and OSHA, among others, and is aware when they are ready to convene an SBREFA panel. SPI then contacts the appropriate companies.
You could be informing regulators about the reality for small plastics manufacturing firms. For information on how to get involved, contact Marie Martinko at SPI, [email protected].
