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Christopher R. Blunck is an attorney with Bergeson & Campbell, P.C. (B&C^®) focusing on domestic and international industrial, commercial, and consumer chemical matters. Prior to joining B&C, Mr. Blunck served as Policy Analyst and Special Assistant to the Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT). Mr. Blunck has managed or participated in the development of hundreds of Toxic Substances Control Act (TSCA) and Toxics Release Inventory (TRI) Program regulations, guidance documents, and policy papers, and his decades of involvement in the regulatory development process at EPA are an invaluable asset to clients seeking to anticipate, address, and resolve regulatory compliance matters.

Over the course of his 30-year career at EPA, Chris developed and reviewed regulations, interpretive guidance, and other policies on TSCA matters, international chemical treaties, and international trade matters related to chemicals; represented the United States in the negotiation and implementation of the Stockholm Convention on Persistent Organic Pollutants and at technical and policy meetings under the Rotterdam Convention on Prior Informed Consent; and earned numerous agency special citations and awards, including an EPA Gold Medal for Exceptional Service in 2017 for his work on the framework for implementing the Frank R. Lautenberg Chemical Safety for the 21st Century amendment of TSCA.

Mr. Blunck received his law degree from George Mason University School of Law and holds a Bachelor of Arts in Environmental, Population, and Organism Biology from the University of Colorado.

Representative Engagements:

• Developed comments on behalf of large companies to respond to proposed TSCA regulations to ensure informed decision-making by EPA and mitigate unintended impacts on the companies and the U.S. economy more broadly.
• Assisted companies to ensure timely and concise responses to EPA TSCA audits.
• Provided counsel to chemical manufacturers, importers, processors, and distributors on regulatory requirements under TSCA.
• Prepared analyses for a Fortune 500 company and a large, multinational corporation to demonstrate product compliance with the European Union (EU) chemical control laws implementing the Stockholm Convention on Persistent Organic Pollutants.
• Provided counsel to a large, multinational company concerning the consideration of a pesticide under the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade.
• Developed and provided to chemical manufacturers and importers standard operating procedures to assist compliance with TSCA.
• Interacted with and convinced EPA on behalf of a Fortune 500 company to refund substantial TSCA fee payment.
• Assisted clients to address issues of importance contained in draft TSCA Section 5(e) Consent Orders to facilitate negotiation with EPA.

Bar & Court Admissions:

District of Columbia, 1990

Speaking Engagements:

Lynn L. Bergeson and Christopher R. Blunck, "Expert Focus: What Are the Implications of the US EPA’s Expected Final Rule on Persistent, Bioaccumulative and Toxic Chemicals?," Chemical Watch, March 26, 2020.