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ACD Press Release

Arlington, VA
November 17, 2023

Susannah Williams

ACD Highlights Industry Disruption Concerns in Comments to EPA on Used Drum Management and Reconditioning ANPRM


Arlington, VA – Today, Alliance for Chemical Distribution (ACD) Senior Vice President of Regulatory Affairs Jennifer Gibson submitted comments to the U.S. Environmental Protection Agency (EPA) urging the agency to reconsider the numerous proposed changes outlined in their Advanced Notice of Proposed Rulemaking (ANPRM) concerning Used Drum Management and Reconditioning.

In the submitted comments, Gibson expressed concerns about the potential disruption, financial strain, and environmental impact that the proposed EPA regulations might impose on the drum reconditioning industry.

“The existing regulations surrounding the drum reconditioning industry are comprehensive and can address the concerns the EPA outlines in this proposal through outreach, education, and enforcement,” said Gibson. “ACD strongly encourages the EPA to focus on existing standards and ensure guidances and resources are available and accessible to support stakeholders’ efforts to comply instead of developing entirely new regulations that could upend the industry.”

Furthermore, the suggested rulemaking will impose increased burdens on reconditioners and other stakeholders, potentially leading to the closure of reconditioning facilities, a surge in costs related to drum reconditioning, and a dissuasion from adopting reconditioning practices. Gibson also underlined how this industry works for small businesses, many of which are ACD members.

“The drum reconditioning industry is cost-effective for small businesses and significantly reduces the carbon footprint associated with containers used in commerce by preventing thousands of containers from prematurely ending up in landfills and reducing the need for the manufacture of new ones,” Gibson continued.

Gibson concluded by urging the EPA to focus on ensuring current regulations are clear and effective and to be mindful of the additional burdens placed on businesses of all sizes.

“ACD is concerned that many of the provisions in this ANPRM are duplicative and burdensome, which would result in severe disruptions to the drum reconditioning industry,” said Gibson. She continued, “ACD believes that the EPA can address remaining cases and reduce future incidents further by improving its guidance and outreach to reconditioners, used drum generators, and transporters to better ensure that current regulations are followed. By working in tandem with the various parties involved in the reconditioning industry, the EPA can make a lasting positive impact without inadvertently driving the companies committed to operating the right way out of business.”

To read ACD’s full comments, click here.



The Alliance for Chemical Distribution (ACD) partners with our more than 400 chemical distribution industry members to provide the education, connection, standards, and advocacy they need to responsibly move the essential products our world depends on. As leaders in the $27B+ chemical distribution industry, ACD member companies commit to the highest standards in quality, safety, sustainability, and performance through ACD Responsible DistributionTM. For more information, visit