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On January 24, 2017, comments by Lynn L. Bergeson, Managing Partner at Bergeson & Campbell P.C. (B&C®), were included in the Bloomberg BNA Daily Environmental Report Article “White House Ices Energy, Environmental Rules Pending Review.”
Attorneys said they were unsure of the memo's impact on an EPA rule (RIN:2070-AJ54) that requires manufacturers, importers and processors to submit information about nanoscale chemicals, including production volumes. This rule was published Jan. 12 and takes effect May 12, more than 60 days from the date of the Priebus memo.
[…]Lynn Bergeson, an attorney with Bergeson & Campbell, P.C., … said the nanoscale materials rule may fall outside the scope of the memo because of its later effective date.