Advocacy Recommends EPA Increase Retrospective Rule Reviews

On March 31, 2025, the U.S. Environmental Protection Agency (EPA) published a request for comments on a review of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Manufacturing and Structural Clay Products Manufacturing and Clay Ceramics Manufacturing under section 610 of the Regulatory Flexibility Act (RFA).

The RFA section 610 review is used to determine whether existing rules are still working as intended or if revisions (or rescissions) are necessary. The reviews must take place within 10 years of a rule’s enactment.

Advocacy supports the EPA’s use of the RFA section 610 review process and encourages the agency to increase the frequency of rule reviews. In this case, Advocacy is not recommending any changes to the underlying rule.

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