All Knowledge & Insights By Date

On March 18, 2020, a coalition of non-governmental organizations (NGO) filed suit in the U.S. District Court for the District of Columbia against the U.S. Environmental Protection Agency (EPA), claiming that EPA fails to disclose information about new chemical substances under the Toxic Substances Control Act (TSCA). According to the plaintiffs’ complaint, EPA fails to publish full and complete notices of its receipt of new chemical applications in a timely fashion and does not disclose...

On March 23, 2020, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) were featured by Bloomberg Environment regarding a proposed registration for Polyguard, which uses nanosilver particles to protect textiles from microbes and bacteria. Lynn Bergeson, managing partner of Bergeson & Campbell P.C., said Polyguard’s registration application is much more targeted, for use only on textiles. “It’s also formulated differently, it’s not...

In last month’s column, we reported on the January 27, 2020, notice from the U.S. Environmental Protection Agency (EPA) identifying the preliminary lists of manufacturers, including importers, of the 20 chemical substances the EPA designated as high-priority for risk evaluation and for which fees will be charged. The notice created a firestorm of criticism over the lack of any exemptions from being considered potentially responsible for paying a share of the EPA’s $1,350,000 fee for...

On March 17, 2020, the U.S. Environmental Protection Agency (EPA) announced the availability of a final rule amending the Chemical Data Reporting (CDR) rule. According to EPA, the amendments are intended to reduce the burden for certain CDR reporters, improve the quality of CDR data collected, and align reporting requirements with the Frank R. Lautenberg Chemical Safety for the 21st Century Act’s (Lautenberg Act) amendments to the Toxic Substances Control Act (TSCA). EPA states that...

This week, I sat down with my colleague Karin Baron, a senior regulatory consultant here at B&C. In this conversation, Karin talks about recent European Union enforcement initiatives that have to do with the CLP legislation: Classification, Labeling, and Packaging legislation. Karin begins by telling us about the current state of harmonization along the lines of the GHS model, and how this might be more an aspiration than a reality. Then we talk about the history of the CLP legislation: how...

On March 18, 2020, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding a lawsuit brought against the U.S. Environmental Protection Agency (EPA) saying the agency failed to provide information about chemical use and new chemicals to which the public is legally entitled. “I do not question the plaintiffs’ goals—EPA has a clear obligation and should re-commit to meeting those obligations—but...

This week, I sat down with my colleague, Dr. Richard Engler, Director of Chemistry here at B&C and The Acta Group (Acta®). We brought everyone up to date on the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) fee rule and how it applies to entities obligated to pay a portion of the $1,350,000 per chemical fee for preparing an EPA-initiated risk evaluation, the legal and regulatory significance of the supplemental rulemaking on...

This week, I sat down with my colleague, Dr. Richard Engler, Director of Chemistry here at B&C and The Acta Group (Acta®). We brought everyone up to date on the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) fee rule and how it applies to entities obligated to pay a portion of the $1,350,000 per chemical fee for preparing an EPA-initiated risk evaluation, the legal and regulatory significance of the supplemental rulemaking on...

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Christopher R. Blunck has joined our firms as Of Counsel with B&C and Senior Regulatory Specialist with Acta. Mr. Blunck most recently served as Policy Analyst and Special Assistant to the Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT). Mr. Blunck has managed or participated in the development of hundreds of Toxic Substances...