September 22, 2021

PFAS Reporting Rules Webinar Recording and Q&A Document Available Now*

Bergeson & Campbell, P.C. (B&C®) is pleased to offer the recording, slides, and written Question and Answer (Q&A) document from our “PFAS Reporting Rules -- What Every Company Needs to Know” webinar, focusing on the U.S. Environmental Protection Agency’s (EPA) proposed reporting rules for per- and polyfluoroalkyl substances (PFAS), presented by B&C Managing Partner Lynn L. Bergeson and Director of Chemistry Richard E. Engler, Ph.D. Do you wonder if the PFAS...
September 17, 2021

Senate Committee Holds Hearing on EPA Nominees for Assistant Administrator for Mission Support and Assistant Administrator for Enforcement and Compliance Assurance

On September 15, 2021, the Senate Committee on Environment and Public Works held a hearing on several U.S. Environmental Protection Agency (EPA) nominees, including Amanda Howe, nominated for Assistant Administrator for Mission Support, and David Uhlmann, nominated for Assistant Administrator for Enforcement and Compliance Assurance. Amanda Howe has a long history of public service, including such roles as the Chief Operating Officer for the now-Vice President, Kamala Harris, for...
September 16, 2021

EPA and PBTs: A New Normal? — A Conversation with Richard E. Engler, Ph.D.

Download Transcript This week I sat down with Dr. Richard E. Engler, B&C’s and The Acta Group’s (our consulting affiliate) Director of Chemistry, to discuss the U.S. Environmental Protection Agency’s (EPA) continuing struggle to regulate certain persistent, bioaccumulative, and toxic (PBT) chemicals, especially those found in finished products, what EPA refers to as “articles.” The Toxic Substances Control Act (TSCA) has always applied to the products, or articles, that...
September 15, 2021

Lynn L. Bergeson, “EPA Goes Back To The Drawing Board On Toxic Substances,” Chemical Processing, September 15, 2021.

The implementation of the Toxic Substances Control Act (TSCA) provisions relating to regulating persistent, bioaccumulative and toxic (PBT) chemicals has been anything but smooth. On September 3, 2021, the Environmental Protection Agency (EPA) announced it intends to initiate new PBT rulemaking and anticipates proposing new rules for five PBT chemicals subject to final risk management rules under TSCA Section 6(h). Additionally, and happily, the agency extended the compliance dates for the...
September 14, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “EPA’s timeline to rework TSCA PBT rules ‘impossible to justify’, NGOs say”

On September 14, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding criticism of the U.S. Environmental Protection Agency’s (EPA) decision to grant industry additional time to comply with a Toxic Substances Control Act (TSCA) prohibition on phenol, isopropylated phosphate (3:1) – or PIP (3:1) – in articles.  Some in industry, however, argue the approach represents the agency’s best effort in...
September 14, 2021

Chemical Watch Features Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., Regarding Compliance Challenges of EPA’s PIP Rule

On September 14, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, were quoted by Chemical Watch in the article “US EPA ‘turns up the heat’ on industry to demonstrate PIP rule challenges.” The EPA, however, has made clear that it will not give [companies] further time lightly.  Many commenters "did not provide sufficiently specific information about their operations to...
September 10, 2021

Meibao Zhuang, Ph.D., Joins Bergeson & Campbell, P.C. and The Acta Group Agricultural Chemicals Practices

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Meibao Zhuang, Ph.D., has joined our firms as Senior Scientist and Regulatory Consultant. Dr. Zhuang offers clients in-depth scientific knowledge and exceptional skills in global and regional regulatory strategy honed over a nearly 20-year career leading regulatory efforts with Corteva Agriscience (Corteva) and Dow AgroSciences LLC (Dow). Dr. Zhuang is a research scientist with a Ph.D. in...
September 3, 2021

EPA Publishes Final Risk Evaluation Scope Documents for DIDP and DINP

On August 31, 2021, the U.S. Environmental Protection Agency (EPA) announced the availability of the final scope documents for the manufacturer-requested risk evaluations (MRRE) of di-isodecyl phthalate (DIDP) and diisononyl phthalate (DINP). 86 Fed. Reg. 48695; 86 Fed. Reg. 48693. The scope documents include the conditions of use, hazards, exposures, and the potentially exposed or susceptible subpopulations that EPA plans to consider in conducting the risk...
September 3, 2021

EPA Plans New Rulemaking for PBTs, Extends Compliance Dates for PIP (3:1) Rule

The U.S. Environmental Protection Agency (EPA) announced on September 3, 2021, that it intends to initiate a new rulemaking and anticipates proposing new rules for five persistent, bioaccumulative, and toxic (PBT) chemicals that are the subject of final risk management rules under the Toxic Substances Control Act (TSCA). Additionally, and importantly, EPA is extending the compliance dates for the prohibitions on processing and distribution and the associated recordkeeping requirements of one of...
September 2, 2021

A Conversation with the NRDC’s Daniel Rosenberg

Download transcript This week, I sat down with Daniel Rosenberg, Director, Federal Toxics Policy, Healthy People & Thriving Communities Program, at the Natural Resources Defense Council (NRDC). Daniel’s distinguished legal career has placed him at the forefront of the evolving law and policy of domestic chemical regulation. Daniel and I discuss new Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency’s (EPA) implementation of the 2016 amendments to TSCA...