November 5, 2013

Countdown to December 1: How to Meet OSHA’s Training Deadline

There are 26 days remaining until the December 1 deadline by which employers must have trained their workers on the new label elements and the Safety Data Sheet (SDS) format as required under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). While there is still time to meet the requirements, companies must act quickly. Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta) can assist employers storing, using, or handling...
November 4, 2013

FTC Gets Tough on Green Guides and “Cracks Down” on Misleading and Unsubstantiated Environmental Marketing Claims

On October 29, 2013, the Federal Trade Commission (FTC) announced six enforcement actions concerning misleading and unsubstantiated environmental marketing claims. In a case imposing a $450,000 civil penalty, FTC filed a complaint and consent order against a company for violating a 1994 FTC order prohibiting it from making unsupported green claims for its paper plates and bags. In the five other actions, FTC addressed biodegradable plastic claims for the first time. In one case, FTC...
November 1, 2013

Lisa R. Burchi, “DTSC Releases Final Safer Consumer Products Regulations,” ABA Section of Environment, Energy, and Resources Chemicals, Chemicals Regulation, and Right-to-Know Committee Newsletter, November, 2013.

On August 28, 2013, California’s Office of Administrative Law (OAL) approved the California Department of Toxic Substances Control (DTSC or department) Safer Consumer Products Regulations (regulations). The regulations took effect on October 1, 2013. The regulations are the much-anticipated regulatory implementation of California’s Green Chemistry Initiative. The regulations and final statement of reasons are available at http://www.dtsc.ca.gov/SCPRegulations.cfm. The scope of the...
October 17, 2013

Regulator Stresses REACH and California’s SCPR are Different

Lynn L. Bergeson was quoted in a Chemical Watch article on California’s new Safer Consumer Products Regulations (SCPR): “Information generated by REACH analyses could help position entities ‘favourably to be aware of what their obligations are under the Safer Consumer Products Regulations, and perhaps position them better to meet those requirements,’ said Lynn Bergeson of Bergeson & Campbell, P.C.”...
October 15, 2013

Lynn L. Bergeson, “Toxic Chemicals: Prepare for Product Regulations,” Chemical Processing, October 15, 2013.

The California Department of Toxic Substances Control (DTSC) Safer Consumer Products Regulations are now in effect (See “California Cracks Down on Chemicals”). While the most onerous requirements for “responsible entities” (manufacturers, importers, assemblers and retailers) will not hit for a while, companies should consider taking some initial steps now to understand how these regulations may affect operations in the future....
October 11, 2013

Bloomberg BNA Daily Environment Report features The Acta Group’s Memo on China’s Hazardous Chemicals List

The October 10, 2013, issue of Daily Environment Report featured a memorandum issued by Acta in the story “Toxic Substances Manufacturers Urged to Review Obligations as China Executes Hazardous Chemicals Rule:” “The Acta Group LLC, a consulting affiliate of the law firm Bergeson & Campbell P.C., released a bulletin Oct. 8 that also urged organizations with interests in China to review the draft catalog and assess their business and compliance obligations to avoid later...
October 11, 2013

James V. Aidala Quoted on Shutdown Concerns in BNA Daily Environment Report

In an October 11, 2013, story titled “Pesticide Imports Halted at U.S. Ports; Importers Seek to Gauge, Address Impact,” James V. Aidala shared his insight on possible effects of the government shutdown on the processing of import notices: “Jim Aidala, former assistant administrator for the EPA Office of Prevention, Pesticides and Toxic Substances, told Bloomberg BNA that the EPA’s Office of Enforcement and Compliance Assurance (OECA)—not the pesticide office—processes import notices....