​The National Rural Electric Cooperative Association (NRECA) encourages the Environmental Protection Agency (EPA) to amend the regulatory criteria defining “small manufacturers and processors” for purposes of the recordkeeping and reporting requirements under section 8(a) of the Toxic Substances Control Act (TSCA). NRECA agrees with the Small Business Administration Office of Advocacy (SBA)1 that in establishing new criteria EPA should (1) reflect different business metrics in different industrial sectors rather than exclusively the Producer Price Index for Chemicals and Allied Products; (2) consider a broader set of factors in developing size standards under TSCA such as number of employees, revenue, inventory volume, or some combination of these factors; and (3) convene a Small Business Advocacy Review Panel2 to consult with affected small entities affected by the criteria. FULL FILING

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