All Knowledge & Insights By Date

The Office of the U.S. Trade Representative (USTR) and the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) issued a May 19, 2011, memorandum to U.S. departments and agencies to highlight the importance of regulatory transparency and openness to promoting international trade. The memorandum is important as it telegraphs the growing importance of trade considerations in domestic regulatory issues, and the Administration’s renewed emphasis on...

The May 11, 2011, issue of BNA Daily Environment Report quotes Kathleen Roberts regarding the U.S. Environmental Protection Agency’s (EPA) decision to suspend the 2011 submission period under the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) rule....

According to a Federal Register notice scheduled for publication in the May 11, 2011, Federal Register, the U.S. Environmental Protection Agency (EPA) is amending the Toxic Substances Control Act (TSCA) Section 8(a) Inventory Update Reporting (IUR) regulations by suspending the next IUR submission period, which would otherwise run from June 1, 2011, to September 30, 2011. The IUR requires manufacturers, including importers, of certain chemical substances included on the...

Photo taken during the May 9, 2011 TSCA Reform Webinar. Pictured :...

On May 6, 2011, the U.S. Environmental Protection Agency (EPA) promulgated a final significant new use rule (SNUR) under Section 5(a)(2) of the Toxic Substances Control Act (TSCA) for the chemical substance identified generically as multi-walled carbon nanotubes (MWCNT), which was the subject of premanufacture notice (PMN) P-08-199. Under the final SNUR, persons intending to manufacture, import, or process MWCNT for a use that is designated as a significant new use by the final rule...

As nano aficionados know, last October the Australian Chemical Gazette included a notice that the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) announced that it was introducing new administrative processes for the notification and assessment of industrial nanomaterials that are considered to be “new” chemicals. The new administrative provisions were effective on January 1, 2011, and apply to any new chemical that falls under the working definition of...

The May 2, 2011, International Environment Reporter and May 3, 2011, BNA Daily Environment Report reference Bergeson & Campbell, P.C.‘s memorandum concerning China’s implementation of the Globally Harmonized System of Classification and Labeling of Chemicals....

We are pleased to announce that the 2011 edition of Washington, D.C., Super Lawyers, a Thomson Reuters Service, includes Lynn L. Bergeson on its list of top lawyers in environmental law. To compile the list, Super Lawyers asked lawyers in Washington, D.C., to name the top attorneys. Super Lawyers also performed its own research to find outstanding attorneys who may have been overlooked. Once Super Lawyers assembled its candidate pool, it assessed the background,...

In an important and little noticed May 3, 2011, Federal Register notice, the U.S. Department of Commerce International Trade Administration (ITA) requested public comments concerning regulatory cooperation between the U.S. and the European Union (EU) that would help eliminate or reduce unnecessary divergences in regulation and in standards used in regulation that impede U.S. exports. Of critical importance, the ITA plainly recognizes and acknowledges that the main impediments to greater trade...

On April 25, 2011, the U.S. Environmental Protection Agency (EPA) released a website regarding conditional registrations granted under Section 3(c)(7) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The website, entitled “Conditional Registration,” is available online. A related press release is available online. As discussed more below, the new website appears to raise as many questions as it seeks to answer. EPA states: “The Office of Pesticide...