• July 19, 2024

    CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS/NEW RULES/REPEALS TO DISCHARGES OF PETROLEUM AND OTHER HAZARDOUS SUBSTANCES RULE – N.J.A.C. 7:1E (DEP DOCKET NO. 03-24-04, PROPOSAL NO. PRN 2024-062)

    Based on our detailed comments below, CCNJ/SRIN are respectfully requesting that the Proposed Rule be reconsidered and workgroup meetings with interested parties be scheduled. The last NJDEP stakeholder meeting was held on February 11, 2019 and only discussed Appendix A, de minimis, Subchapter 6, recordkeeping, renewal cycle, and revised language. There was no discussion on some of the key 2024 proposed amendments; workgroup meetings with interested parties need to be held to discuss these changes. The input developed during these meetings will better inform NJDEP’s regulatory proposal and decision-making.


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  • January 30, 2023

    CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS AND NEW RULE, STORMWATER MANAGEMENT RULES, FLOOD HAZARD AREA CONTROL ACT RULES, N.J.A.C. 7:8, 7:13 (DEP DOCKET NUMBER 08-22-10, PROPOSAL NO. PRN 2022-156)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the proposed amendments and new rule regarding stormwater management and Flood Hazard Area Control Act requirements published in the New Jersey Register on December 5, 2022.


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  • January 12, 2023

    CCNJ COMMENTS: FY2023 ANNUAL FEE REPORT AND ASSESSMENT OF FEES FOR THE NJPDES PERMIT PROGRAM

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments on the New Jersey Pollutant Discharge Elimination System (NJPDES) Fiscal Year (FY) 2023 Annual Fee Report and Assessment of Fees.


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  • January 6, 2023

    CCNJ COMMENTS: PROPOSED AMENDMENTS TO THE REGULATIONS OF THE NEW JERSEY SITE REMEDIATION PROFESSIONAL LICENSING BOARD, N.J.A.C. 7:26I (DEP DOCKET NUMBER 06-22-09, PROPOSAL NO. PRN 2022-138)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) appreciate the opportunity to provide comments to the New Jersey Site Remediation Professional Licensing Board (SRPLB) on the proposed rule amendments published in the New Jersey Register on November 7, 2022.


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  • September 2, 2022

    CCNJ COMMENTS: NJDEP PROPOSED NEW ENVIRONMENTAL JUSTICE RULES (DEP DOCKET NO. 04-22-04, PROPOSAL NO. PRN 2022-082)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) appreciate the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, Department) on the Proposed New Environmental Justice (EJ) Rules published in the New Jersey Register on June 6, 2022 (Proposed Rules).


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  • March 4, 2022

    CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS AND NEW RULES, CONTROL AND PROHIBITION OF CARBON DIOXIDE EMISSIONS, N.J.A.C. 7:27, 7:27A, 7:27F (DEP DOCKET NUMBER 07-21-11, PROPOSAL NO. PRN 2021-117)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the proposed amendments and new rules regarding the carbon dioxide (CO2) emissions requirements published in the New Jersey Register on December 6, 2021.


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  • February 17, 2022

    CCNJ COMMENTS: FY2022 ANNUAL FEE REPORT AND ASSESSMENT OF FEES FOR THE NJPDES PERMIT PROGRAM

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments on the New Jersey Pollutant Discharge Elimination System (NJPDES) Fiscal Year (FY) 2022 Annual Fee Report and Assessment of Fees.


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  • August 26, 2021

    CCNJ COMMENTS: NJDEP NOTICE OF OPPORTUNITY FOR PUBLIC COMMENT ON DISCONTINUATION OF GENERAL PERMIT GP-020 FOR RESEARCH AND DEVELOPMENT

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, Department) regarding the discontinuation of GP-020 for Research and Development (R&D) at minor air facilities, N.J.A.C. 7:27-8.8(c)19.


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  • August 20, 2021

    CCNJ COMMENTS: NJDEP PROPOSED NEW RULES AND AMENDMENTS, GREENHOUSE GAS MONITORING AND REPORTING

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed new rules and amendments regarding Greenhouse Gas (GHG) Monitoring and Reporting requirements published in the New Jersey Register on June 21, 2021.


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  • August 20, 2021

    CCNJ COMMENTS: PRE-PROPOSAL COMMENTS ON NJDEP ENVIRONMENTAL JUSTICE RULEMAKING STAKEHOLDER EFFORT

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and Site Remediation Industry Network (SRIN) appreciate the opportunity to provide the following comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the Environmental Justice (EJ) rulemaking focus areas, as presented at the virtual stakeholder meetings held from January through June 2021.


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  • June 25, 2021

    CCNJ COMMENTS: NJDEP TECHNICAL GUIDANCE DOCUMENT FILL MATERIAL GUIDANCE FOR SRP SITES

    CCNJ/SRIN provided comments on the "Fill Material Guidance for SRP  sites" NJDEP Technical Guidance Document.


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  • June 17, 2021

    CCNJ COMMENTS: NJDEP PROPOSED AMENDMENT AND NEW RULES, ADVANCED CLEAN TRUCKS PROGRAM AND FLEET REPORTING REQUIREMENTS

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the proposed amendment and new rules regarding the Advanced Clean Trucks Program and fleet reporting requirements published in the New Jersey Register on April 19, 2021. CCNJ member companies are committed to conducting operations in a sustainable and environmentally responsible manner while pursuing business goals which add to New Jersey’s economic recovery.


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  • June 1, 2021

    CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS TO PERMIT AND REPORTING REQUIREMENTS FOR FUMIGANTS AND OTHER HAZARDOUS AIR POLLUTANTS, N.J.A.C. 7:27, 7:27A

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, Department) on the Proposed Amendments to the Permit and Reporting Requirements for Fumigants and Other Hazardous Air Pollutants published in the New Jersey Register on March 1, 2021 (Proposed Amendments). The Proposed Amendments present widely sweeping changes to the regulation of fumigants and fumigation operations that will impact a range of industries beyond fumigation


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  • December 28, 2020

    CCNJ COMMENTS: ARS MGW TECHNICAL GUIDANCE

    CCNJ/SRIN submitted the ARS MGW Technical Guidance comments to DEP. Included at the end are the two documents that are referenced in our comment spreadsheet.


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  • December 21, 2020

    CCNJ COMMENTS: 1,4-DIOXANE PUBLIC COMMENT

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) appreciate the opportunity to provide comments to the Drinking Water Quality Institute (DWQI) pursuant to the Institute’s request for public input regarding the recently released subcommittee reports on 1,4-dioxane. CCNJ/SRIN have long advocated for greater transparency and public input with respect to DWQI’s activities, and we appreciate this opportunity.


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  • November 23, 2020

    PRE-PROPOSAL COMMENTS ON NJDEP EJ RULEMAKING EFFORT

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and Site Remediation Industry Network (SRIN) appreciate the opportunity to provide the following pre-proposal comments to the New Jersey Department of Environmental Protection (NJDEP) on the environmental justice (EJ) rulemaking focus areas, as presented at the October 22, 2020 virtual initial public information session. Please note that these initial comments are limited based on what information has been shared so far. CCNJ/SRIN respectfully request that the NJDEP follow through with their statement about committing to scheduling future focus group and stakeholder meetings, and remain engaged with stakeholders on this rulemaking effort.


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  • November 16, 2020

    CCNJ COMMENTS: NJDEP VAPOR INTRUSION TECHNICAL GUIDANCE VERSION 5.0

    The Vapor Intrusion Technical Guidance version 5.0 (VITG) is being issued to address the proposed Draft Remediation Standards (Docket 01-20-03), which proposes the establishment of Indoor Air Remediation Standards (IARS) for the first time. The implementation of remediation standards will increase the complexity and technical scrutiny associated with all VI projects. CCNJ/SRIN appreciate the opportunity to review the VITG, however we are disappointed the NJDEP has limited our review and comment of this very important document to the "revised portion of the document only.


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  • July 13, 2020

    CCNJ COMMENTS: DRAFT ALTERNATIVE REMEDIATION STANDARDS TECHNICAL GUIDANCE FOR INGESTION-DERMAL AND INHALATION EXPOSURE PATHWAYS FOR SOIL, VERSION 1.0

    CCNJ/SRIN submitted a consolidated comment spreadsheet on the ARS Technical Guidance for Ingestion-Dermal and Inhalation Exposure Pathways for Soil to DEP.


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  • March 10, 2020

    PRELIMINARY COMMENTS ON NJDEP NJPACT RULEMAKING EFFORT – REDUCING CO2 EMISSIONS IN NJ

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following preliminary comments to the New Jersey Department of Environmental Protection (NJDEP) on the potential pathways to reduce carbon emissions in the state to achieve the goals of 80% reduction in greenhouse gas (GHG) emissions from 2006 levels by 2050 and 100% clean energy by 2050, as presented at the stakeholder meeting held on February 25, 2020.


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  • March 6, 2020

    PRELIMINARY COMMENTS ON NJDEP NJPACT RULEMAKING EFFORT – PERIODIC MONITORING AND REPORTING OF NJ’S GHG EMISSIONS

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following preliminary comments to the New Jersey Department of Environmental Protection (NJDEP) on the greenhouse gas (GHG) monitoring and reporting rulemaking focus areas, as presented at the stakeholder meeting held on February 21, 2020.


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  • September 13, 2019

    COMMENTS: 2019 ENERGY MASTER PLAN – PROMOTING ENERGY EFFICIENCY AND AFFORDABILITY

    Chemistry Council of New Jersey

    Our members continue to be concerned with the high cost of energy in New Jersey.  In a CCNJ membership survey conducted during the months of June and July of 2018, respondents for the eleventh consecutive year, unanimously ranked energy costs as one of the top issues of concern facing their companies in New Jersey.  Energy is a vital component of our industry’s cost structure, and higher energy prices can have a substantial impact on both jobs and the bottom line of our member companies.  New Jersey’s industrial energy rates are still some of the highest in the nation, about 45% above the national average.  As large energy users, the state’s energy policies are of critical importance to our members.


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  • May 31, 2019

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO VARIOUS RULES, GROUND WATER QUALITY STANDARDS AND MAXIMUM CONTAMINANT LEVELS FOR PERFLUOROOCTANOIC ACID AND PERFLUOROOCTANESULFONIC ACID

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed amendments to various rules, including Discharges of Petroleum and Other Hazardous Substances (DPHS) Rules, Ground Water Quality Standards (GWQS) Rules, Private Well Testing Act (PWTA) Rules, Safe Drinking Water Act (SDWA) Rules, and New Jersey Pollutant Discharge Elimination System (NJPDES) Rules, for Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) published in the New Jersey Register on April 1, 2019.


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  • March 26, 2019

    COMMENTS: NJDEP SOIL REMEDIATION STANDARDS

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) would like to share our concerns regarding the upcoming New Jersey Department of Environmental Protection (NJDEP, the Department) rule proposal that is expected to update various Soil Remediation Standards (SRS) and also change Impact to Ground Water (IGW) and Vapor Intrusion (VI) screening levels into remediation standards.


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  • March 22, 2019

    COMMENTS: NJDEP DRAFT ENVIRONMENTAL JUSTICE EXECUTIVE ORDER NO. 23 GUIDANCE

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the draft Environmental Justice (EJ) Executive Order No. 23 Guidance, dated December 17, 2018.


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  • February 15, 2019

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO AIR QUALITY RULES, GLOBAL WARMING SOLUTIONS FUND & CO2 BUDGET TRADING PROGRAM

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed amendments to the Air Quality rules included in two separate rule proposals published in the New Jersey Register on December 17, 2018.(DEP DOCKET NOS. 04-18-10 & 05-18-11, PROPOSAL NOS. PRN 2018-112 & PRN 2018-113)


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  • February 1, 2019

    COMMENTS: AIR TOXICS AND FUMIGATION ISSUES

    The New Jersey Business and Industry Association (NJBIA) and the Chemistry Council of New Jersey/Site Remediation Industry Network (CCNJ/SRIN) (collectively, “Commenters”) submit preliminary comments on the New Jersey Department of Environmental Protection’s (NJDEP) proposals on air toxics and fumigation standards, as presented in NJDEP’s stakeholder meeting on January 17, 2019.


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  • February 1, 2019

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO WATER QUALITY RULES

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide the following comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed amendments to the Water Quality rules published in the New Jersey Register on December 3, 2018.(DEP DOCKET NO. 03-18-10, PROPOSAL NO. PRN 2018-111)


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  • January 31, 2019

    POSITION PAPER:CCNJ OPPOSES SENATE BILL 1073 & ASSEMBLY BILL 2694

    This bill(s) would allow for the creation of a new county or municipal bureaucracy to manage stormwater utilities. There is little debate that this state already has too many facets of government on the municipal, county and state levels. CCNJ believes, despite being permissive, that this legislation would add an entirely new layer of governmental oversite, with unlimited taxing authority.


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  • October 19, 2018

    COMMENTS: IN THE MATTER OF THE IMPLEMENTATION OF L. 2018, c. 16 REGARDING THE ESTABLISHMENT OF A ZERO EMISSION CERTIFICATE PROGRAM FOR ELIGIBLE NUCLEAR POWER PLANTS

    On behalf of the Chemistry Council of New Jersey, which represents the business of chemistry in the state, we remain concerned with the potential subsidy for nuclear generation. As I testified during the extensive legislative process, this subsidy will drastically increase the electricity cost to manufactures in NJ, an industry that state has been trying to bolster. The potential cost of this program will increase electricity bills for companies who already pay an average of 45% more than there competition from around the country. To put it in a dollar and cents perspective, this subsidy could cost some smaller manufactures in NJ nearly $100,000 in additional energy cost, while larger manufactures could pay upwards of $1 million annually.


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  • October 11, 2018

    COMMENTS: REGARDING NEW JERSEY 2019 ENERGY MASTER PLAN – REDUCING ENERGY CONSUMPTION

    Energy is a vital component of the industry’s cost structure and higher energy prices can have a substantial impact on our members and the consumers of their products.  As such, we support goals to drive down the cost of energy for all customers, to promote a diverse portfolio of new, clean, in-state generation and to reward energy efficiency and energy conservation and reduce peak demand.  The Council believes that these goals are in the best interests of all energy consumers, as their implementation will lead to significant improvement in energy utilization throughout the state, ensure that the environment remains protected, and foster innovation and economic growth.


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  • September 11, 2018

    ISSUE PAPER: ENERGY IN PERSPECTIVE

    In a Chemistry Council of New Jersey (CCNJ) membership survey conducted during the months of June and July of 2018, respondents for the eleventh consecutive year unanimously ranked energy costs as one of the top issues of concern facing their companies in New Jersey.  One can understand why, since New Jersey’s industrial energy rates are among the highest in the nation. For some energy-intensive products, energy for both fuel and power needs and feedstocks account for up to 85% of total production costs. Because energy is a vital component of the industry’s cost structure, higher energy prices can have a substantial impact on jobs and the bottom line.


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  • June 28, 2018

    COMMENTS: POTENTIAL REPORTING CHANGES TO THE TOXIC CATASTROPHE PREVENTION ACT PROGRAM

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ), we would like to share our concerns regarding the attached draft “Annual Report Compliance Audit and Near Miss Handout” dated May 2, 2018, which summarizes potential changes to the Toxic Catastrophe Prevention Act (TCPA) annual report requirements.


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  • June 6, 2018

    COMMENTS: NJPDES FISCAL YEAR 2018 ANNUAL FEE REPORT AND ASSESSMENT OF FEES

    First, we would like to share some history and background on our past efforts in advocating for improvements to the NJPDES fee structure.  Back in 2013 and 2014, CCNJ and its members participated in NJPDES stakeholder meetings with the focus on ensuring that the reduction of permittees and environmental loading was taken into account when calculating the industrial NJPDES fees, which were rising uncontrollably.


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  • March 6, 2018

    COMMENTS: ECOLOGICAL EVALUATION TECHNICAL GUIDANCE DOCUMENT VERSION 1.4

    CCNJ and the Site Remediation Industry Network (SRIN) provided comments on the proposed revisions to the Technical Guidance for Ecological Evaluation (EE) to the New Jersey Department of Environmental Protection (NJDEP) on March 6, 2018.


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  • February 22, 2018

    COMMENTS: IMMEDIATE ENVIRONMENTAL CONCERN TECHNICAL GUIDANCE DOCUMENT VERSION 2.0

    CCNJ and the Site Remediation Industry Network (SRIN) provided comments on the proposed revisions to the Technical Guidance for Immediate Environmental Concern (IEC) to the New Jersey Department of Environmental Protection (NJDEP) on February 22, 2018.


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  • February 5, 2018

    COMMENTS: REQUEST FOR PUBLIC INPUT FOR PERFLUOROOCTANE SULFONATE

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) appreciate the opportunity to provide comments to the Drinking Water Quality Institute (DWQI) pursuant to the Institute’s request for public input regarding the recently released subcommittee reports on Perfluorooctane Sulfonate (PFOS). CCNJ/SRIN have long advocated for greater transparency and public input with respect to DWQI’s activities and we appreciate the steps taken to provide this opportunity.


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  • October 6, 2017

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO AIR QUALITY RULES (DEP DOCKET NO. 12-17-06, PROPOSAL NO. PRN 2017-139)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed amendments to Air Quality, Energy, and Sustainability Program rules published in the New Jersey Register on August 7, 2017.


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  • September 29, 2017

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO SITE REMEDIATION AND WASTE MANAGEMENT PROGRAM RULES (DEP DOCKET NO. 10-17-06, PROPOSAL NO. PRN 2017-134)

    COMMENTS ON NJDEP PROPOSED AMENDMENTS TO SITE REMEDIATION AND WASTE MANAGEMENT PROGRAM RULES (DEP DOCKET NO. 10-17-06, PROPOSAL NO. PRN 2017-134)


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  • November 21, 2016

    COMMENTS: REQUEST FOR PUBLIC INPUT FOR PERFLUOROOCTANOIC ACID

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and Site Remediation Industry Network (SRIN) appreciates the opportunity to provide comments to the Drinking Water Quality Institute (DWQI) pursuant to the Institute’s request for public input regarding the recently released subcommittee reports on Perfluorooctanoic Acid (PFOA).


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  • November 4, 2016

    COMMENTS: COASTAL ZONE MANAGEMENT RULES, N.J.A.C. 7:7-16.9; PUBLIC ACCESS

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ), we appreciate the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the proposed public access amendments to the Coastal Zone Management Rules (the “Proposal”).<br />  


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  • February 9, 2016

    COMMENTS: “PLANNING FOR AND RESPONSE TO CATASTROPHIC EVENTS AT CONTAMINATED SITES” TECHNICAL GUIDANCE DOCUMENT

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN), we appreciate the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the “Planning for and Response to Catastrophic Events at Contaminated Sites” (Catastrophic Events) Technical Guidance Document. 


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  • May 1, 2015

    Issue Paper: Energy in Perspective

    In a Chemistry Council of New Jersey (CCNJ) membership survey conducted during the months of June and July of 2014, respondents for the seventh consecutive year unanimously ranked energy costs as one of the top issues of concern facing their companies in New Jersey. One can understand why, since New Jersey’s industrial energy rates are among the highest in the nation. For some energy-intensive products, energy for both fuel and power needs and feedstocks account for up to 85% of total production costs. Because energy is a vital component of the industry’s cost structure, higher energy prices can have a substantial impact on jobs and the bottom line.


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  • March 31, 2014

    OSHA | Docket No. OSHA-2013-0020 Request for Information for Modernization of PSM Standard

    The Chemistry Council of New Jersey (CCNJ) is pleased to respond to the U.S. Department of Labor’s (DOL’s) Occupational Safety and Health Administration (OSHA) notice of Request for Information (RFI), Docket No. OSHA-2013-0020, published in the Federal Register on December 9, 2013 at 78 Federal Register 73756-73768. The CCNJ represents over 70 New Jersey companies involved in the business of chemistry (pharmaceuticals, chemicals, flavors and fragrances, petroleum refining, etc.). The business of chemistry directly employs more than 50,000 persons in New Jersey and is responsible for over $25 billion dollars in revenues in New Jersey each year. CCNJ members place high value and priority on safety and security for their employees, their workplaces, and the communities that host them. The CCNJ member companies are committed to continually improving environmental, health, safety, and security performance through common sense advocacy designed to address major public policy issues, health and environmental research, and product testing.


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