Not only are metals essential to human health, they also play a vital role in virtually every aspect of everyday life through their use in energy and electricity systems, packaging, transportation, consumer goods, and much more. By volume, metals and metal compounds represent the vast majority of marketed chemical substances. Consideration of how these essential materials can and should be regulated under U.S. and international laws is often misunderstood. And metals’ unique physical and chemical characteristics can be inappropriately regulated in ways that result in restrictions disproportionate to their real or potential risk. Excess or inexact regulation can hamper important developments across industries -- from medical to IT. It is critical that regulatory systems recognize the unique physical and chemical properties of metal and metal substances, which are very different than organic chemicals, and adopt risk assessment and risk management schemes that appropriately reflect those issues.
Bergeson & Campbell, P.C. (B&C®) in conjunction with its affiliate, B&C® Consortia Management, L.L.C. (BCCM), is uniquely well-suited to assist metal producers and downstream metal users and other stakeholders in successful engagement on legal, regulatory, and science policy issues pertinent to their issues.
B&C has been a leader in providing representation of and advocating for metal-specific groups for many years. We fully understand the metal community and its unique needs and challenges. B&C is the recognized leader in addressing the complexities of reporting metal substance byproducts under the U.S. Environmental Protection Agency’s (EPA) Chemical Data Reporting (CDR) rule.
B&C plays a pivotal role in ensuring the metal community’s unique issues and interests are understood and reflected in ongoing discussions surrounding potential legislative changes in chemical management under the Toxic Substances Control Act (TSCA). We offer an experienced group of professionals with strong relationships with decision-makers within EPA and other agencies, including the Small Business Administration (SBA), the Occupational Safety and Health Administration (OSHA), the European Commission (EC), and the European Chemicals Agency (ECHA) -- all of which play pivotal roles in regulatory decision-making for metal substances.
Our strong working relationships with key trade groups, such as the International Council on Mining and Metals, Eurometaux, and the Mining Association of Canada, are invaluable to our clients in the metals community. Through these interactions, and our diligent and thorough monitoring and assessment of international, national, and state activities, we allow our clients to remain updated on legal, regulatory, and science policy issues pertinent to their interests and respond in a timely manner. Our ability to share intelligence on regulatory initiatives timely and efficiently is unparalleled.
An essential element of our success is the reliable network of global partnerships and strategic alliances we have developed to meet our clients’ needs. We are able to deploy the resources brought to bear through this network to provide a high standard of service. Our business model relies on a nimble team of embedded agents located around the globe who are able to respond quickly and efficiently to our requests for information. We excel in accessing information, analyzing its implications for particular business sectors, such as the metals industry, and communicating those impacts quickly and clearly. Our partners work in an unobtrusive manner to influence decision-making without causing offence or adopting a high profile, direct approach. This is an important point, as cultural differences among countries, Asian countries in particular, must be considered. Furthermore, several of the Asian countries are in the process of evaluating and revising existing legislation and guidance documents. This makes the need for embedded assets and resources all the more important.
Our partners, in many cases, are former government regulators intimately involved in the jurisdiction’s chemical control legislation and/or regulatory implementation. These relationships are also instrumental in ensuring that our clients maintain a good, ongoing working relationship with relevant government personnel and in fostering a better understanding of existing regulatory measures and their enforcement. Several of our partners are involved in specific metal consortia/task forces and/or technical committees.
What We Do:
The wealth of B&C’s experience working at and with numerous state, federal, and international agencies positions us to advocate effectively for our clients before problems arise and to mitigate issues after the fact. We have worked for years with staff at EPA, OSHA, the U.S. Department of State, state regulatory agencies such as California’s Office of Environmental Health Hazard Assessment (OEHHA), and other governmental venues. Areas in which we advise clients include the following:
BERGESON & CAMPBELL, P.C.
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