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On January 17, 2017, the Bloomberg BNA Daily Environment Report Article “Process to Select Chemicals for Risk Review Proposed: EPA” included comments by Lynn L. Bergeson, Managing Partner at Bergeson & Campbell P.C. (B&C®), discussing specifics of the U.S. Environmental Protection Agency’s (EPA) proposed risk rule.
Lynn Bergeson, managing partner with the Washington D.C.-based law firm Bergeson & Campbell, PC, said she too would have liked EPA's proposed rule to be clearer as to how exactly the criteria would translate into a decision as to whether high priority status is warranted for a chemical.
“EPA is correct that the statute sets a low bar (“potential hazard” and “potential route of exposure”), but that makes it all the more important to be clear about what the legal standard is and how the criteria and considerations will be weighed, evaluated, and consistently applied,” Bergeson said by e-mail.