April 26, 2017

Office of Chemical Safety and Pollution Prevention (OCSPP): Take Advantage of This Regulatory Reform Advocacy Opportunity

On February 24, 2017, President Trump issued Executive Order (EO) 13777, “Enforcing the Regulatory Reform Agenda.” Issuance of the EO, and the subsequent measures undertaken by U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt offer unique opportunities for chemical stakeholders.  This memorandum summarizes EPA’s efforts to date in this regard, and identifies opportunities that stakeholders may wish to pursue to eliminate or amend regulatory...
April 26, 2017

Bloomberg BNA Daily Environment Report Quotes Richard Engler In “No Insights in EPA Notices on 19 New Chemicals on Market”

On April 25, 2017, Bloomberg BNA Daily Environment Report included comments by Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), commenting on the 19 new chemicals that have been given market approval by the U.S. Environmental Protection Agency (EPA) between December 1, 2016, and February 28, 2017. […] The EPA has notified the manufacturers that asked to make the new chemicals of the approvals and announced the decisions on its public...
April 20, 2017

​Inside EPA Article Quotes TSCA Blog Post “EPA Denies TSCA Section 21 Petition on Fluoride Chemicals in Drinking Water; Provides Response to Petition”

On April 19, 2017, Inside EPA quoted a post from the TSCA Blog in the article “Suit Over EPA's Rejection Of Fluoride Ban Claims TSCA Misinterpretation.” “This asserted view, that only a comprehensive risk evaluation considering all conditions of use will suffice, presents a very high threshold for action -- and seemingly an impossibly high threshold to move EPA to act," officials with the law firm Bergeson & Campbell said in a March 7 blog post. […]  Bergeson...
April 14, 2017

Federal Court Invalidates Air Reporting Exemption For Large-Scale Livestock Operations

On April 11, 2017, the U.S. Court of Appeals for the District of Columbia issued a decision vacating the U.S. Environmental Protection Agency’s (EPA) rule exempting livestock feeding operations from air reporting requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act (EPCRA). Large-scale animal feeding operations that confine, for example, more than 1,000 cattle, 2,500 hogs, or...
April 14, 2017

Lynn L. Bergeson, “TSCA Targets Mercury: EPA regulation aims to minimize mercury use,” Chemical Processing, April 14, 2017.

On March 29, 2017, the U.S. Environmental Protection Agency (EPA) released its initial inventory report of mercury supply, use and trade in the United States pursuant to the requirements of the amended Toxic Substances Control Act (TSCA). This article outlines this development in the context of mercury regulation under the TSCA.
April 14, 2017

Lynn L. Bergeson, “TSCA Reform: Key Provisions and Implications,” Environmental Quality Management, Winter 2016.

On June 22, 2016, President Obama signed into law the Frank R. Lautenberg Chemical Safety for the 21st Century Act. The text of the law is available at: http://www.congress.gov/bill/114th-congress/house-bill/2576/text. The law substantially amends the Toxic Substances Control Act (TSCA), and in so doing, fundamentally alters the domestic management of industrial chemicals, the lifeblood of many manufacturing processes. This article summarizes key changes and explains their likely impacts on...
April 7, 2017

FDA Announces Three Waivers To Sanitary Transportation Rule

On April 6, 2017, the U.S. Food and Drug Administration (FDA) published three waivers to the now final Sanitary Transportation rule mandated by the FDA Food Safety Modernization Act (FSMA) for businesses whose transportation operations are subject to separate state-federal controls in the Federal Register. 82 Fed. Reg. 16733. The waivers include: Businesses holding valid permits that are inspected under the National Conference on Interstate Milk Shipments’ Grade “A” Milk Safety Program,...
April 7, 2017

Internal EPA Memoranda Outline Approach for Regulatory Deconstruction; Stakeholders Have the Opportunity to Seek to Protect Programs at Risk

A trio of recent internal U.S. Environmental Protection Agency (EPA) memoranda are providing insight into how EPA intends to implement President Trump’s review and potential pogrom of EPA regulations. Virtually no program or regulation appears to be secure from the chopping block. Many stakeholders in industry and other sectors may be alarmed to see programs that are of benefit to them assigned a slot in the guillotine. Supporters of these programs, thus, would be wise to educate senior EPA...
April 4, 2017

The Acta Group Wins “Supply Chains Award” at the 2017 Chemicals Northwest Awards

The Acta Group (Acta®), a global scientific and business consulting firm offering a full range of support services for the process of obtaining approvals to market industrial chemicals, biocides, and chemical products, with offices in Washington, D.C., Beijing, China, and Manchester, UK,  has been named winner of the Chemicals Northwest 2017 “Supply Chains Award.”  Chemicals Northwest Awards are presented in ten categories, all of which recognize excellence in the chemical and chemical...
April 3, 2017

EPA Denies Petition to Ban Chlorpyrifos

On March 29, 2017, U.S. Environment Protection Agency (EPA) Administrator Pruitt signed an order denying the September 2007 petition of the Pesticide Action Network North America (PANNA) and the Natural Resources Defense Council (NRDC) requesting that EPA revoke all tolerances and cancel all registrations for the pesticide chlorpyrifos.  This is the latest EPA action in a long and contentious battle concerning chlorpyrifos tolerances and registrations, and is likely not the end of this...