All Knowledge & Insights By Date

EPA Seeks Additional Comment On NPDES Electronic Reporting Rule: On December 1, 2014, the U.S. Environmental Protection Agency (EPA) requested additional comment on the proposed National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule that would require electronic reporting instead of current paper-based NPDES reports. 79 Fed. Reg. 71066. This rule would, according to EPA, modernize NPDES reporting, save time and resources for regulated entities and regulatory...

EPA Reviews National Ambient Air Quality Standards For Ozone: On December 17, 2014, the U.S. Environmental Protection Agency (EPA) issued a proposed rule revising the air quality criteria for ozone (O3) and related photochemical oxidants and National Ambient Air Quality Standards (NAAQS) for O3. 79 Fed. Reg. 75234. EPA proposed to revise the primary standard to a level within the range of 0.065 to 0.070 parts per million (ppm), and to revise the secondary standard to...

On January 16, 2015, the U.S. Environmental Protection Agency (EPA) granted a petition from the Biobased and Renewable Products Advocacy Group (BRAG®) to add “biodiesel” as a chemical category for partial reporting exemption at 40 C.F.R. Section 711.6(b)(2)(iv) under the Chemical Data Reporting (CDR) rule and will be proceeding with a direct final rule to be published later in January. The approved biodiesel category on the partial reporting exemption list will include the...

On December 29, 2014, the U.S. Environmental Protection Agency (EPA) published a final rule signaling renewed interest in asserting Toxic Substances Control Act (TSCA) jurisdiction over finished goods. The final rule adds nine benzidine-based chemical substances to the existing significant new use rule (SNUR) on these substances, and, with respect to both the newly added and previously-listed substances, makes inapplicable the exemption relating to persons that import or process the substances...

Canada announced on January 9, 2015, that the New Substances Program has published six new risk assessment summaries for chemicals and polymers, including a summary for multi-wall carbon nanotubes. See http://www.ec.gc.ca/subsnouvelles-newsubs/default.asp?lang=En&n=4BCC7425-1 Environment Canada and Health Canada conduct risk assessments on new substances. These assessments include consideration of information on physical and chemical properties, hazards, uses, and exposure to...

Comments made by Lynn Bergeson were published by Bloomberg BNA Daily Environment Report in an article about recent and continuing efforts to pass a Toxic Substances Control Act (TSCA) reform bill. Federal preemption of state chemical regulation purposely was not addressed in a widely circulated draft revision of S. 1009 that never was introduced, and the preemption issue remains a challenge, Lynn Bergeson, managing partner of Bergeson & Campbell P.C., told Bloomberg BNA in an...

Comments made by Jane S. Vergnes, Ph.D., were featured in a Bloomberg BNA Daily Environment Report article covering the initial determination by the U.S. Food and Drug Administration that additional data are needed to establish that six chemicals submitted for inclusion as active ingredients in the over-the-counter sunscreen monograph using the Time and Extent Application processes are generally recognized as safe and effective.   The decisions show the bar to get...

Inside EPA featured comments made by Lynn L. Bergeson in an Inside EPA article on issues impacting TSCA reform: Lynn Bergeson, of the Washington, DC, firm Bergeson & Campbell, noted that the “rights of states need to be part of the discussion on preemption in reform talks during the next Congress,” adding that the importance of the issue “cannot be overestimated’ in securing approval of a TSCA reform bill.”...

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce the addition of Richard E. Engler, Ph.D., to our firms as Senior Policy Advisor. Dr. Engler is a 17-year veteran of the U.S. Environmental Protection Agency (EPA) and is one of the most widely recognized experts in the field of green chemistry, having served as senior staff scientist in EPA’s Office of Pollution Prevention and Toxics (OPPT) and leader of EPA’s Green...

B&C Senior Policy Advisor Richard Engler, Ph.D., was quoted in a BNA Daily Environment Report article discussing the best ways to reduce or eliminate the use chemicals of concern by companies and regulators: “Understanding the functional use of a chemical is vital to maximizing the sustainability of a solution to a particular problem,” Richard Engler, who served as leader of the Environmental Protection Agency’s Green Chemistry Program prior to joining the law...