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April 16, 2017

Bergeson & Campbell, P.C. Forms “TSCA New Chemicals Coalition”

Lynn L. Bergeson

On August 14, 2017, Bergeson & Campbell, P.C. (B&C®) announced it would be forming a Toxic Substances Control Act (TSCA) New Chemicals Coalition.  That the U.S. Environmental Protection Agency (EPA) is now required to make a determination on all new chemicals (or significant new uses of existing chemicals) is at the heart of the changes in EPA’s review of new chemicals, and the new policies and practices that have emerged since June of 2016.  What is less clear is how EPA is making these determinations.  The coalition’s mission is to prepare meaningful comments and offer constructive, helpful, and informed improvements to the new chemicals review process. 

Joining the coalition is easy.  We are asking for a flat fee of $1,000 per company for a 12 month period.  We are not currently allowing trade associations to join.  The chemical community has participated in ad hoc coalitions for years, so the drill is familiar.  Dues will be used to:

  • Convene meetings and calls;
  • Develop advocacy positions on crucial issues to be decided and prioritized, including preparing for EPA’s Fall 2017 release of documents on how it reviews new chemicals; and
  • Provide informed and effective comment on these issues and meet with EPA leadership to advocate for the Coalition’s views on these issues.

More information is available in our memorandum Bergeson & Campbell, P.C. Forms “TSCA New Chemicals Coalition.”