All Knowledge & Insights By Date

On July 25, 2016, Inside EPA quoted Bergeson & Campbell P.C.’s (B&C®) memoranda “EPA Releases First Determinations for New Chemicals under New TSCA,” on the U.S. Environmental Protection Agency’s (EPA) use of structure activity relationship (SAR) in premanufacture notice (PMN) reviews. In a July 22 memo to clients and colleagues, the law firm Bergeson & Campbell also notes that EPA appears to have used structure activity relationship (SAR) modeling in its...

On July 22, 2016, the U.S. Environmental Protection Agency (EPA) posted on its website the first four Section 5(a)(3) determinations for premanufacture notices (PMN) under the Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Pub. L. No. 114-182) (new TSCA). All four of the new chemicals were determined to satisfy the "not likely to present an unreasonable risk" determination at Section 5(a)(3)(C). It is notable that all...

On June 22, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in Bloomberg BNA Daily Environment Report discussing the new Toxic Substances Control Act (TSCA) chemical regulatory process. Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA: “On the whole, the process seems to be efficient, but stakeholders will need to monitor the website.”

The European Commission (EC) published on July 14, 2016, a regulation in the Official Journal of the European Union that amends Annex VI, the list of ultraviolet (UV) filters allowed in cosmetic products, of the cosmetics regulation.

On July 21, 2016, Michael S. Wenk, Senior Regulatory Consultant at Bergeson & Campbell P.C. (B&C®), was quoted in the Chemical Watch article Brazil maps out plans for industrial chemicals policy. Michael Wenk, senior regulatory consultant at law firm Bergeson & Campbell, said because there isn't a formal list of substances selected for the national register, “one could see” the environment ministry including parts of established national inventories, such as...

On July 15, 2016, the California Department of Toxic Substances Control (DTSC) announced the release of its proposed regulation on children's foam-padded sleeping products containing tris(1,3-dichloro-2-propyl) phosphate (TDCPP) or tris(2-chloroethyl) phosphate (TCEP) as a Priority Product (PP) under the Safer Consumer Products Regulations (SCPR). DTSC first released information about this PP on March 13, 2014, so this proposed regulation is a major step in the SCPR process and over...

On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), in the article, “Give EPA Detailed New Chemical Notices, Attorneys Advise.” Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be...

On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), in the article “Give EPA Detailed New Chemical Notices, Attorneys Advise.” Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much...

On July 13, 2016, the Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), in coordination with the Federal Railroad Administration (FRA), announced proposed regulations for Oil Spill Response Plans and Information Sharing for High-Hazard Flammable Trains (HHFTs). The rule would expand the comprehensive oil spill response plan requirements under the Clean Water Act (CWA) to certain HHFT trains based on the amount of crude oil being transported....

On July 14, 2016, Bloomberg BNA Daily Environment Report included quotes from the B&C® and Chemical Watch webinar “The New TSCA Series Webinar 2: Impacts on New Chemical Programs.” Chemical manufacturers and processors will need to give exposure and toxicity data to the EPA for it to evaluate the risks of new and existing chemicals as required by the recently amended Toxic Substances Control Act, said Charles Auer, who directed the EPA Office of Pollution...