December 14, 2015

HCS: OSHA Issues Letter of Interpretation on Import/Export Labels for Hazard Communication Standard (HCS 2012)

On November 23, 2015, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) issued a Letter of Interpretation (LOI) on labeling packages for import and export. The LOI discusses labeling scenarios and details OSHA's interpretation of the Hazard Communication Standard (HCS 2012) requirements for those scenarios. Background On May 26, 2012, OSHA issued a final rule modifying its HCS to conform to the United Nations' Globally Harmonized System of...
December 14, 2015

Chemical Watch Includes Extensive Comments By Lynn L. Bergeson On Impacts Of TSCA Reform

The December 14, 2015, Chemical Watch article “TSCA Bill Could Have 'Huge' Impact On Downstream Users,” included quotes from Lynn L. Bergeson on possible results of TSCA Reform. Changes to the chemical inventory as proposed in the US Senate Toxic Substances Control Act (TSCA) reform would have a “huge” impact on downstream users, according to Lynn Bergeson, owner of Bergeson & Campbell, PC.  Bill S697 proposes to reset the TSCA Inventory of Chemical Substances to...
December 11, 2015

Proposition 65:  OEHHA Repeals and Re-Proposes Revisions to Proposition 65 Warning Regulations

On November 27, 2015, the California Office of Environmental Health Hazard Assessment (OEHHA) took two actions: (1) it withdrew its proposed rule issued on January 16, 2015, that would have repealed and replaced the existing Article 6 regulations regarding the all-important "clear and reasonable warnings" requirements under Proposition 65 (Prop 65); and (2) it replaced it with a new proposed rule that will repeal and replace the Prop 65 Article 6 regulations (Proposed Rule), posted with an...
December 11, 2015

Proposition 65:  OEHHA Repeals and Re-Proposes Revisions to Proposition 65 Warning Regulations

On November 27, 2015, the California Office of Environmental Health Hazard Assessment (OEHHA) took two actions: (1) it withdrew its proposed rule issued on January 16, 2015, that would have repealed and replaced the existing Article 6 regulations regarding the all-important "clear and reasonable warnings" requirements under Proposition 65 (Prop 65); and (2) it replaced it with a new proposed rule that will repeal and replace the Prop 65 Article 6 regulations (Proposed Rule), posted with an...
December 11, 2015

Chemical Watch Quotes Lynn L. Bergeson On Possible Future Of TSCA Reform

On December 11, 2015, Chemical Watch, quoted Lynn Bergeson in the article “Senate TSCA Bill More Aligned With EPA Principles, Says Denison.” Lynn Bergeson, managing partner of Bergeson & Campbell, said it is possible that the Senate will approve S-697 before Congress adjourns in mid-December. “Until it emerges from the Senate we can’t have any further action on the bill,” she added.
December 9, 2015

EPA Launches eDisclosure Portal And Other Recent EPCRA Developments

EPA Launches eDisclosure Portal: On December 9, 2015, the U.S. Environmental Protection Agency (EPA) announced that it is modernizing implementation of its self-disclosure policies by creating a centralized web-based ''eDisclosure'' portal to receive and automatically process self-disclosed civil violations of environmental law. 80 Fed. Reg. 76476. Under the automated eDisclosure system, "large and small businesses will quickly be able to get some of their more routine types of disclosures...
December 9, 2015

Bloomberg BNA Daily Environment Report Focuses On Impact Of New Chemical Issues At Law Firms

The December 9, 2015, Daily Environment Report article “Evolving Chemical Issues Drive Change at Law Firms” included an interview with Lynn Bergeson and Heidi Lewis on how Bergeson & Campbell, P.C., has changed in the 10 years since REACH became law.  REACH became law in 2006 in the European Union, Iceland, Liechtenstein and Norway. Since then, Bergeson & Campbell PC has seen “tremendous growth” said Heidi Brown Lewis, director of marketing for the firm. “We've...
December 1, 2015

Bloomberg BNA Daily Environment Report Quotes Lynn Bergeson On Proposed Swedish Nanomaterials Reporting Rule

The December 1, 2015, Bloomberg BNA Daily Environment Report article “Swedish Agency Proposes Nanomaterials Reporting” included quotes from Lynn L. Bergeson. The proposal is not unexpected, said Lynn Bergeson, managing partner of the law firm Bergeson & Campbell P.C., which has tracked policies for nanomaterials for more than a decade. Sweden's National Action Plan, issued Oct. 8, 2013, recommended the creation of an inventory of products on the market that contain...
December 1, 2015

Request Recording and Materials from Panel Discussion with EPA Alumni:

"TSCA Reform: What’s Happening Now, and What’s Next?" Request Recording and slides from “TSCA Reform Panel Summit: What’s Happening Now, and What’s Next?”  Program informational flyer George Washington University (GWU) Milken Institute School of Public Health, GWU Law School, Environmental Law Institute, Arnold & Porter LLP, and Bergeson & Campbell, P.C. Present:  TSCA Reform Panel Summit: What's Happening Now, and What's Next? Thursday, November 19, 2015,...