Comment submitted by Main Street Foundation’s Center for Regulatory Analysis and Engagement (CRAE)
AnonymousOpposeAdvocacy
Summary: The Main Street Foundation’s Center for Regulatory Analysis and Engagement (CRAE) opposes the proposed Information Collection Request (ICR) for methylene chloride. They argue that the collection is duplicative of existing OSHA requirements, places a disproportionate burden on small businesses, and lacks a demonstrated necessity for the regulatory goals.
Attached are comments of the Main Street Foundation Center for Regulatory Analysis and Engagement (CRAE). CRAE incorporates by reference the comments submitted by the Center for Regulatory Freedom (CRF) on October 23, 2025, in Docket No. EPA-HQ-OPPT-2021-0303-0009. Those comments were authored and signed by CRAE's founder and president, Andrew M. Langer, and address substantially the same information collection and underlying regulatory framework at issue here. CRAE adopts those comments insofar as they are consistent with the positions expressed herein.