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August 15, 2017
Lynn L. Bergeson Quoted In “EPA TSCA Guide May Give Industry New Strategies For Risk Evaluations”

On August 15, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®) was quoted by Inside EPA discussing how new U.S. Environmental Protection Agency (EPA) risk evaluation guidelines may impact industry.

“My sense is that if you have a promising chemical product and wish to get it through the risk evaluation process sooner rather than later, considering this option makes sense,” Lynn Bergeson, managing partner of environmental law firm Bergeson & Campbell, tells Inside EPA.

“You control the timing, and might have a better line of sight on agency engagement,” Bergeson adds. “Why would you 'self-select?' You believe the assessment will validate your view that the product is great, poses no unreasonable risks, and is better than brand X. This is good product stewardship, good business, and may be good competitively.”

Bergeson […] notes that EPA’s final risk evaluation rule, regarding evaluations the agency will conduct at industry’s request, “permits requesters to seek evaluation of less than all a chemical’s uses . . . unlike the proposed rule that placed the burden of information gathering plainly on industry. This is a big change and makes the request opportunity much more manageable. . . . It seems to me the requester should be responsible for at least this much.”

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