Meeting with National Association of Music Merchants  
Location:  U.S. EPA, 1200 Pennsylvania Ave., NW, 20460
Date and Time:  August 13, 2013, 1 pm 
EPA staff met with James Goldberg of Goldberg & Associates, PLLC representing the National Association of Music Merchants regarding the two proposed rules to implement Title VI of the Toxic Substances Control Act (TSCA).  Mr. Goldberg clarified during the meeting that his association members mostly purchase and assemble finished goods made from composite wood products and therefore would be considered fabricators as opposed to laminated product producers under our proposed rule. Examples of what his members assemble include keyboards, instrument cases, audio speakers, guitars, and violins. Mr. Goldberg discussed his concern about the proposed recordkeeping and labeling provisions for importers and fabricators to disclose the name of the panel producer in their records.  Similarly he was concerned that importers might not know the names of their fabricators and therefore could not put that on their label. Mr. Goldberg stated that his members who purchase parts made from composite wood products or who import parts made from composite wood products may not be provided the identity of the panel producer or fabricator because it is claimed as proprietary information. Mr Goldberg also expressed his interest to partner with EPA to conduct outreach to his members on the requirements under TSCA Title VI once finalized.

