All Knowledge & Insights By Date

On October 1, 2014, the U.S. Environmental Protection Agency (EPA) proposed a significant new use rule (SNUR) for 15 related chemical substances commonly known as nonylphenols (NP) and nonylphenol ethoxylates (NPE). These substances are recognized as persistent and toxic in the environment. This article discusses this important move....

Join Gradient and Bergeson & Campbell for a webinar and online discussion series regarding the scientific, legal, and business implications brought on by the widespread implementation of GHS principles. Major changes for chemical manufacturers and importers are in store on June 1, 2015, when the key provisions of US Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (“HazCom” 2012) take effect. HazCom 2012, which mandates alignment with the...

Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson in an October 31, 2014 article on silicon carbide. “Lynn Bergeson, managing partner of Bergeson & Campbell P.C., which has tracked global developments of policies and regulations for nanotechnologies, said IARC’s conclusions about carbon nanotubes reflect the state of the science as it exists today and are thus necessarily limited. ‘The good news is there is no data at this time to suggest carbon nanotubes cause...

Chemicals play a central role in our personal and professional lives. As consumers, we focus keenly on the chemicals in the products we use and with which we come into contact. Globalization and the emergence worldwide of sophisticated chemical management programs invite complex legal, commercial, and scientific challenges. These challenges extend far beyond compliance questions that, by comparison, seem now nostalgically straightforward. Understanding these programs and their evolution can only...

Inside EPA quoted an October 23, 2014, email commentary from Bergeson & Campbell P.C.® discussing the effectiveness of the Toxic Substances Control Act Work Plan. The Work Plan “reflects a certain nimbleness and elasticity in the program, features that are essential to the success of any chemical assessment process,” said the email. “The update also speaks favorably of the Work Plan’s ability to accommodate new information and recalibrate on an ongoing basis. . . ....

On October 21, 2014, the Biobased and Renewable Products Advocacy Group (BRAG®) submitted petitions to the U.S. Environmental Protection Agency (EPA) requesting that biodiesel fuel manufacturers be granted the same Chemical Data Reporting (CDR) exemptions that petroleum-based diesel manufacturers already receive. BRAG made its petitions through two mechanisms allowed under Toxic Substances Control Act (TSCA) rules. BRAG’s petitioning of EPA was reported in the Bloomberg BNA Daily...

The October 24, 2014, Bloomberg BNA Daily Environment Report featured comments from Lynn L. Bergeson about the restructuring of the EPA’s registration division. “Lynn Bergeson, head of the law firm Bergeson & Campbell, told Bloomberg BNA that the impetus for these moves was likely to make sure the division meets its statutory deadlines to issue registrations. ‘I think the decision to reorganize was driven entirely by EPA’s desire to ensure more people are working on registration...

The U.S. Environmental Protection Agency (EPA) announced on October 23, 2014, that it has updated its Toxic Substances Control Act (TSCA) Work Plan for Chemical Assessments. According to EPA, the updated TSCA Work Plan reflects updated data submitted to EPA on chemical releases and potential exposures that EPA received as part of the Chemical Data Reporting (CDR) Rule and the Toxics Release Inventory (TRI) Program. EPA removed or consolidated 16 chemicals, most of which are believed...

Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson in an October 20, 2014, story that explored the outcome of a Republican held Senate. “ ‘There are signs the House will remain engaged, suggesting that 2015 could be the year for TSCA reform,’ said Bergeson. ‘How extensive the reform, whether it will address all the TSCA issues that have been discussed for years, whether it will stem the tide of state chemical-specific measures and whether consumer confidence will be...

Bloomberg BNA Chemical Regulation Reporter featured comments on the use of nanoengineered chemicals by Lynn L. Bergeson in an October 16, 2014, article covering a webinar on nanotechnology issues offered by the Air & Waste Management Association (A&WMA). “Lynn Bergeson, managing partner of Bergeson & Campbell P.C., who participated in the A&WMA’s webinar, pointed to an example of a beneficial use of a nanoengineered chemical. The day of the webinar, the EPA...