All B&C® News

August 30, 2016
Register for the “New TSCA” Webinar 3: Inventory, CDR, and CBI (Sections 8 & 14) Sept. 12, 2016
  Monday, September 12, 2016 8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time Register Today Speakers: Charles M. Auer, Charles Auer & Associates, LLC, former Director of the Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA)   Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C.   Richard E. Engler, Ph.D., Senior Chemist, Bergeson & Campbell, P.C., former senior staff scientist in OPPT and leader of EPA's Green Chemistry Program   Kelly Franklin, ... read more >
August 25, 2016
B&C Memoranda Featured In Inside EPA Article, “Attorneys Say Proposed TSCA Rule May Violate Trade Secret Provisions”
On August 25, 2016, the Bergeson & Campbell, P.C., (B&C®) memoranda “TSCA Reform: Proposed Changes to SNUR Procedures Would, Perhaps Inadvertently, Result in Disclosure of CBI to Third Parties/Possible Competitors” and “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” were discussed in an Inside EPA article on how Toxic Substances Control Act (TSCA) Reform may violate trade secret provisions. "We do not read provisions in either old or new TSCA to authorize EPA to disclose CBI ... read more >
August 18, 2016
Chemical Watch Article “Law firm flags up issues in EPA Snur proposal” Quotes B&C Memorandum Conflict Between SNURs And Revised OSHA HCS
On August 18, 2016, Chemical Watch quoted the Bergeson & Campbell, P.C. (B&C®) memorandum, “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” in an article examining the conflict between the U.S. Environmental Protection Agency’s (EPA) Significant New Use Rule (SNUR) proposal and the revised Occupational Safety and Health Administration's (OSHA) Hazard Communications Standard (HCS). US agency's notice 'downplays' magnitude of changes, says Bergeson & Campbell. The US ... read more >
August 11, 2016
Bloomberg BNA Daily Environment Report Article, “Fees Must Not Stymie Innovation, Chemical Makers Tell EPA,” Includes Comments From Kathleen M. Roberts
On August 11, 2016, the Bloomberg BNA Daily Environment Report quoted Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C. (B&C®), on the implication of additional fees created by Toxic Substance Control Act (TSCA) reform. Companies that pay the costs of generating toxicity, exposure and other data should not be “double billed” through additional fees to review the resulting information, said Walls and Kathleen Roberts, vice president of Bergeson & Campbell Consortia ... read more >
August 11, 2016
IHS Chemical Week Quotes Lynn L. Bergeson On EPA Implementing TSCA Reform
On July 11, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), was quoted in the IHS Chemical Week article “Responsible Care: TSCA reform and enhancing product safety.” “Chemical companies need to start paying attention to what EPA is doing and announcing—and raise concerns so they can be heard.” Lynn Bergeson, a managing partner at environmental law firm Bergeson & Campbell, agrees, adding chemical companies should “carefully monitor [EPA’s] rulemaking process immediately.” Bergeson said that there ... read more >
August 4, 2016
B&C Memorandum Quoted In Inside EPA Article “Attorneys Say EPA SNUR Aligning Protection With OSHA May Exceed TSCA”
On August 4, 2016, quotes from the Bergeson & Campbell P.C. (B&C®) memorandum “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards” were included in an Inside EPA article about conflicts between Occupational Safety and Health Administration (OSHA) and the revised Toxic Substances Control Act (TSCA). A law firm that frequently represents industry clients is warning that a recently proposed rule that seeks to align EPA requirements for new uses of industrial chemicals with strict Occupational Safety ... read more >
July 29, 2016
Bloomberg BNA Daily Environment Report Features Comments By Richard E. Engler On TCE Ban
On July 29, 2016, Richard E. Engler, Senior Chemist with Bergeson & Campbell, P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article, “White House Reviewing EPA Degreaser Ban.” A ban on TCE could affect a huge number of companies, according to Richard Engler, a senior chemist at the law firm Bergeson & Campbell. “This would affect any business that removes grease from metal,” Engler told Bloomberg BNA. “That could be mechanics large and small. … . I think it's lots and lots of ... read more >
July 25, 2016
Inside EPA Quotes B&C Memorandum In Article “EPA Issues First New Chemical Safety Reviews Under Reformed TSCA Law”
On July 25, 2016, Inside EPA quoted Bergeson & Campbell P.C.’s (B&C®) memoranda “EPA Releases First Determinations for New Chemicals under New TSCA,” on the U.S. Environmental Protection Agency’s (EPA) use of structure activity relationship (SAR) in premanufacture notice (PMN) reviews. In a July 22 memo to clients and colleagues, the law firm Bergeson & Campbell also notes that EPA appears to have used structure activity relationship (SAR) modeling in its analyses, though the firm, unlike Denison, applauded the use of these ... read more >
July 22, 2016
Bloomberg BNA Daily Environment Report Quotes Lynn L. Bergeson In “First Decisions on New Chemicals Made Under Amended TSCA”
On June 22, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in Bloomberg BNA Daily Environment Report discussing the new Toxic Substances Control Act (TSCA) chemical regulatory process. Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA: “On the whole, the process seems to be efficient, but stakeholders will need to monitor the ... read more >
July 20, 2016
Chemical Watch Features Comments By Michael S. Wenk On Planned Brazilian Chemical Registry
On July 21, 2016, Michael S. Wenk, Senior Regulatory Consultant at Bergeson & Campbell P.C. (B&C®), was quoted in the Chemical Watch article Brazil maps out plans for industrial chemicals policy. Michael Wenk, senior regulatory consultant at law firm Bergeson & Campbell, said because there isn't a formal list of substances selected for the national register, “one could see” the environment ministry including parts of established national inventories, such as those in the US, Canada and Australia. “These inventories have significant ... read more >
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