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: FDA reviewed comments on the waivers after they were included in the proposed rule and found that the waivers would not result in...
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...
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...
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...
On June 22, 2016, President Obama signed into law the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). The new law amended significantly the Toxic Substances Control Act (TSCA) and in so doing, is redefining supply chain relationships, rewriting the rules of engagement for due diligence in mergers and acquisitions, reopening debate on new avenues in product liability and tort law, and raising important questions regarding right-to-know vs. confidential business...
On March 29, 2017, Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Report explaining possible impacts of a mercury inventory under the Toxic Substances Control Act (TSCA). […]The updated chemicals law also calls for the EPA to develop a regulation by June 2018 that will require companies that use mercury or mercury compounds to provide the agency with information about those...
March 29, 2017
Bloomberg BNA Daily Environment Report Article Includes Comments From James Aidala On Possible Chlorpyrifos Restrictions
On March 29, 2017, the Bloomberg BNA Daily Environment Report included comments from, James Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®), in the article “Trump Administration to Make Tough Decision on Dow Chemical.” […]But undoing the underpinnings that justify a near-ban will take more than political will, said Jim Aidala, a senior consultant with Bergeson & Campbell PC. A decision that favors the manufacturer, Dow...
On March 28, 2017, Sheryl Lindros Dolan, Senior Regulatory Consultant at Bergeson & Campbell, P.C. (B&C®), presented “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the Society for Chemical Hazard Communication (SCHC) Spring Meeting. Ms. Dolan’s presentation reviewed the requirements for confidential business information (CBI) protection under the new Toxic Substances Control Act (TSCA), compared these...
Bergeson & Campbell, P.C. (B&C®), is seeking a pesticide registration specialist to join our growing team of regulatory consultants, scientists, and policy experts. This position will be based in our Washington, D.C. office, although telework arrangements may be considered for the right candidate. Applicants should be experienced in all aspects of preparing, submitting, and managing applications under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), having...
Implementation of the newly amended Toxic Substances Control Act (TSCA), signed into law last June, is in full swing. The U.S. Environmental Protection Agency (EPA) has been working hard to meet statutorily imposed deadlines for promulgating three “framework” rules by June 2017. To date, the EPA is on target. This column discusses the three framework rules....