Retail Association Comments on EPA Aerosol Can Proposed Rule
The Retail Industry Leaders Association (“RILA”), the Food Marketing Institute (“FMI”), and the National Association of Chain Drug Stores (“NACDS”), and their members (collectively, the “Retail Associations”) are pleased to submit these comments in response to the proposal of the U.S. Environmental Protection Agency (“EPA” or the “Agency”) to classify and regulate hazardous aerosol can wastes as universal wastes under the Resource Conservation and Recovery Act (“RCRA”). See 83 Fed. Reg. 11,654 (March 16, 2018).