All Knowledge & Insights By Date

On December 15, 2017, Chemical Watch featured comments by the TSCA New Chemicals Coalition (NCC) on the U.S. Environmental Protection Agency’s (EPA) new chemical evaluation policy. An industry group has argued that the US EPA should avoid issuing orders to mitigate workplace risks associated with new chemicals. Instead, it says, it should turn over that regulatory responsibility to the Occupational Health and Safety Administration (Osha). The TSCA New Chemicals Coalition...

On December 11, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted in Chemical Watch regarding concerns with the U.S. Environmental Protection Agency’s (EPA) plan to move away from consent orders in favor of Significant New Use Rules (SNURs) when regulating potential uses of new chemicals. When the situation described in a pre-manufacture notice (PMN) is not of concern, but there is a potential use of the new chemical that...

On December 11, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted in the Chemical Week article “Trump's EPA: TSCA remains priority amid regulatory rollback.” “Not surprisingly, there’s been a tremendous focus on the implementation requirements for Lautenberg,” says Lynn Bergeson, managing partner of Bergeson & Campbell (Washington, DC). Efforts have included building a conceptual framework of how to review and apply the...

On December 6 2017, the California Office of Environmental Health Hazard Assessment (OEHHA) issued a notice alerting stakeholders that amendments were approved related to its August 28, 2016, adopted revisions to its Proposition 65 (Prop 65) Article 6 “clear and reasonable warnings” regulations. These amendments, first proposed on July 21, 2017, are intended to clarify and correct certain sections of Article 6 that OEHHA believed “would be beneficial to the regulated community in...

The Acta Group (Acta®) and Bergeson & Campbell, P.C. (B&C®) are pleased to announce that Scott J. Burya, Ph.D. has joined our firms as a Regulatory Chemist.  Dr. Burya holds a Ph.D. in analytical chemistry from the Ohio State University and will support clients in all stages of product development, from assessing the toxicology and regulatory profiles of new substances, performing quantitative risk assessments, and navigating state and federal regulations, to guiding teams through...

On August 11, 2017, the U.S. Environmental Protection Agency (EPA) published the third Toxic Substances Control Act (TSCA) framework final rule in the Federal Register, the TSCA Inventory Notification (Active-Inactive) Requirements (EPA, 2017). This final rule is now in effect. This Washington Watch column explains why the rule is important, and what stakeholders should be doing to protect their interests.

On November 29, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Senior Chemist at B&C, were quoted by Bloomberg BNA Daily Environment Report regarding recently released U.S. Environmental Protection Agency (EPA) documents on new chemical review procedures. The Points to Consider When Preparing TSCA New Chemical Notifications document, in particular, provides a clear, useful summary of the agency's...

As previously reported in our blog item on October 26, 2017, the U.S. Environmental Protection Agency (EPA) proposed triennial electronic reporting requirements pertinent to the supply, use, and trade of mercury in the United States. 82 Fed. Reg. 49564. This memorandum provides more information and an in-depth look into EPA’s proposed rule. The 2016 amendments to the Toxic Substances Control Act (TSCA) require EPA to establish periodic mercury reporting requirements for any...

California’s Proposition 65 (Prop 65) has been a keen area of client interest for years. One question repeatedly asked is “what is a clear and reasonable warning?” The California Office of Environmental Health Hazard Assessment (OEHHA) released a Questions and Answers for Businesses (Q&A) document specifically covering “clear and reasonable warnings” requirements. The Q&A aims to help companies comply with new Prop 65 notice requirements that become effective next August. This...

After a decade of trying, the U.S. Environmental Protection Agency (EPA) now has in effect a final Toxic Substances Control Act (TSCA) Section 8(a) information gathering rule focusing on nanoscale materials. This article explains the final rule, what stakeholders are required to do, and by when.