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January 11, 2019

Bloomberg Environment Features Comments by Kathleen M. Roberts Regarding Delayed CDR Rule

Bergeson & Campbell, P.C.

On January 11, 2019, Bloomberg Environment spoke with Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), for the article “Chemical Makers’ Data Duties Delayed by Shutdown.”

“Assuming the proposed changes are not major, the delay in releasing the proposed [Chemical Data Reporting] rule is an inconvenience rather than a block impeding chemical manufacturers ability to do business,” said Kathleen M. Roberts, a vice president at Bergeson and Campbell, P.C. in Washington, D.C.

“The delay may cost chemical manufacturers time and money later in the year as they retrospectively analyze information collected throughout 2019 to ensure it is consistent with the changes, and if it is not, gather the information needed for the proposed changes,” she said.

The EPA uses the information it collects every four years through its Chemical Data Reporting (CDR) rule to support its oversight of chemicals. The data helps inform its decisions on which chemicals and uses warrant scrutiny to determine their potential risk to public health or the environment. 

A proposed rule to revise the data reporting regulation and specify the information the agency will require was poised to be submitted to a White House office for review prior to the EPA’s shutdown, Roberts said.

But the proposed rule had not appeared on the White House’s Office of Management and Budget’s website as of Jan. 10.


The agency also has floated the idea of changing the industry categories chemical manufacturers use to describe the customers that use their products, Roberts said.

The EPA lists 48 potential industrial sectors that may use a chemical.

It can be challenging to figure out which industrial categories use a chemical, Roberts said.

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