All Knowledge & Insights By Date

On January 26, 2017, the Bloomberg BNA Daily Environment Report quoted James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell P.C. (B&C®), on the Trump administration’s handling of climate change communications. It’s no surprise that Trump has de-emphasized climate change in his administration, said Jim Aidala, a consultant with Bergeson & Campbell PC in Washington, D.C., and former head of EPA’s chemicals division under President...

Last year was full of surprises, two of which will drive much of the agenda in 2017 for the Office of Chemical Safety and Pollution Prevention (OCSPP) of the U.S. Environmental Protection Agency (EPA). First, Congress significantly amended the Toxic Substances Control Act (TSCA). Although many thought the chances of successful TSCA legislation were slim, the second surprise event was even more unexpected — the election of Donald Trump as President....

On January 24, 2017, comments by Lynn L. Bergeson, Managing Partner at Bergeson & Campbell P.C. (B&C®), were included in the Bloomberg BNA Daily Environmental Report Article “White House Ices Energy, Environmental Rules Pending Review.” Attorneys said they were unsure of the memo’s impact on an EPA rule (RIN:2070-AJ54) that requires manufacturers, importers and processors to submit information about nanoscale chemicals, including production volumes. This rule...

On January 19, 2017, the U.S. Environmental Protection Agency (EPA) proposed a process for conducting risk evaluations to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, including an unreasonable risk to a potentially exposed or susceptible subpopulation, under the conditions of use. 82 Fed, Reg. 7562. The process would not consider costs or other non-risk factors. Risk evaluation is the second step, after prioritization, in a new...

The U.S. Environmental Protection Agency (EPA) proposed on January 17, 2017, procedures to establish the risk-based screening process and criteria that EPA will use to identify chemical substances under the Toxic Substances Control Act (TSCA) as either High-Priority Substances for risk evaluation, or Low-Priority Substances for which risk evaluations are not warranted at the time. 82 Fed. Reg. 4825. The proposed rule describes the processes for identifying potential candidates for...

On January 13, 2017, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would require an electronic notification for chemical substances listed on the Toxic Substances Control Act (TSCA) Inventory that were manufactured (including imported) for non-exempt commercial purposes during the ten-year time period ending on June 21, 2016. 82 Fed. Reg. 4255. EPA would also accept such notices for chemical substances that were processed. The recent TSCA amendments require EPA to...

In an expected action, on January 11, 2017, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a proposed rule under Section 6(a) of the Toxic Substances Control Act (TSCA) to regulate the use of trichloroethylene (TCE) in vapor degreasing.  The proposed rule has not yet been published in the Federal Register, but a pre-publication version of the proposed rule is available on EPA’s website, along with a fact sheet and other information.  The...

On January 17, 2017, the Bloomberg BNA Daily Environment Report Article “Process to Select Chemicals for Risk Review Proposed: EPA” included comments by Lynn L. Bergeson, Managing Partner at Bergeson & Campbell P.C. (B&C®), discussing specifics of the U.S. Environmental Protection Agency’s (EPA) proposed risk rule. Lynn Bergeson, managing partner with the Washington D.C.-based law firm Bergeson & Campbell, PC, said she too would have liked EPA’s proposed...

On January 17, 2017, Bloomberg BNA Daily Environment Report included a quote by Lynn L. Bergeson in the article “EPA Proposes Strategy to Identify, Review Commercial Chemicals.” Lynn Bergeson, managing partner of Bergeson & Campbell PC in Washington, D.C., told Bloomberg BNA, “EPA has done the near impossible in proposing three epic rules. Now the burden is on other stakeholders to define, clarify, and help the process along.”...

REGISTER TODAY Thursday, February 16, 2017, 2:00 p.m. Eastern Standard Time The Central and South American chemical regulatory environment continues to be one that is challenging to understand, navigate, and manage from a business perspective.  These challenges most often stem from one of three aspects:  a lack of knowledge concerning the regulatory and governmental authority structure; a challenge in determining which regulations (local, national, and/or trade bloc) apply;...