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February 25, 2004 Marianne L. Horinko Assistant Administrator U.S. Environmental Protection Agency Ariel Rios Building, 5101T 1200 Pennsylvania Avenue, N. W. Washington, DC 20460 Re: Comments of the Synthetic Organic Chemical Manufacturers Association on the Proposed Rule on Revisions to the Definition of Solid Waste Dear Ms. Horinko: The Synthetic Organic Chemical Manufacturers Association (“SOCMA”) is pleased to offer the following comments on the Proposed Rule for Revisions to the Definition of Solid Waste (the “Proposed Rule”) (68 Fed. Reg. 61557 (Oct. 28, 2003)). By a notice dated December 29, 2003, EPA extended the deadline for comments on the Proposed Rule to February 25, 2004 (68 Fed. Reg. 74907). SOCMA is the leading trade association representing the batch and custom chemical industry. SOCMA’s 300+ member companies make the products and refine the raw materials that make our standard of living possible. From pharmaceuticals to cosmetics, soaps to plastics and all manner of industrial and construction products, SOCMA members make at save lives, make our food supply safe and abundant, and enable the manufacture of literally thousands of other products. Over 75% of SOCMA’s active members are small businesses. In connection with their regular manufacturing operations, a number of SOCMA members routinely generate and manage materials which are presently regulated as hazardous waste. In many instances, SOCMA ...
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