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The U.S. Environmental Protection Agency (EPA) released on December 20, 2019, an updated version of the “Working Approach” document that builds upon EPA’s November 2017 “New Chemicals Decision-Making Framework: Working Approach to Making Determinations under Section 5 of TSCA.” EPA states that the updated document, “TSCA New Chemical Determinations: A Working Approach for Making Determinations under TSCA Section 5,” explains its approach for making one of the five affirmative...

The U.S. Environmental Protection Agency (EPA) published on December 20, 2019, the final list of high-priority chemicals. These chemicals will be the next 20 chemicals to undergo risk evaluation under the amended Toxic Substances Control Act (TSCA). According to EPA, issuing the final list of high-priority chemicals for risk evaluation “represents the final step in the prioritization process outlined in TSCA and marks another major TSCA milestone for EPA in its efforts to ensure the safety of...

On November 20, 2019, the U.S. Environmental Protection Agency (EPA) signed off on final changes to the risk management program (RMP) rule, most recently amended in January 2017. The regulations were promulgated under Section 112(r) of the Clean Air Act (CAA) when the law was amended in 1990. This section is intended to prevent or minimize the consequences of accidental chemical releases. A need to prevent or minimize the catastrophic consequences of accidental chemical release is a point few...

This week, I sat down with my colleague Christopher Bryant, a Senior Regulatory Consultant here at Bergeson & Campbell. Chris has over 25 years of experience in environmental, health, and safety compliance, and, in particular, hazardous waste management and regulation under the Resource Conservation and Recovery Act (RCRA). I asked Chris to the studio to speak with me about RCRA:  what it is, how the law has developed, what is covered under it, and how we might expect -- or hope -- it...

This week, I sat down with my colleague Christopher Bryant, a Senior Regulatory Consultant here at Bergeson & Campbell. Chris has over 25 years of experience in environmental, health, and safety compliance, and, in particular, hazardous waste management and regulation under the Resource Conservation and Recovery Act (RCRA). I asked Chris to the studio to speak with me about RCRA:  what it is, how the law has developed, what is covered under it, and how we might expect -- or hope -- it...

As part of its Fitness Check of European Union (EU) legislation regarding endocrine disruptors, the European Commission (EC) has begun two public consultations: a public consultation (designed from a citizen’s perspective), and a stakeholder consultation (designed for stakeholders and experts). The public consultation will close March 9, 2020, and targets the general public. The stakeholder survey will close on January 31, 2020, and targets stakeholder...

Bergeson & Campbell, P.C. (B&C®) is pleased to announce that Managing Partner Lynn L. Bergeson has again been named one of North America's leading legal practitioners by Who’s Who Legal – Environment. Ms. Bergeson's recognition as a "Leading Individual" by peers and clients notes that she is “highly respected for her top-notch practice where she supports clients in sophisticated regulatory matters in complex biotechnology industries.”  This is the fifteenth year Ms. Bergeson...

The results of the United Kingdom’s December 12, 2019, elections give the Conservative Party under the leadership of Boris Johnson a clear mandate to withdraw from the European Union (EU), a process colloquially known as “Brexit,” by the January 31, 2020, deadline agreed with the EU. The mandate is clear, the details of withdrawal are not, and the forthcoming negotiation with the EU promises to be challenging. Brexit has attracted unparalleled levels of attention from the global...

The latest revisions to the Act on Registration, Evaluation, etc. of Chemicals [Act No. 15844, October 16, 2018] in South Korea (K-REACH) entered into force on January 1, 2019. Its first significant compliance deadline required manufacturers and importers to pre-register existing substances by June 30, 2019. The industry is now shifting its focus to registration requirements that provide the following phase-in timelines. Substances imported or manufactured > 1,000 tons/year and...

On December 4, 2019, the U.S. Environmental Protection Agency (EPA) published an advance notice of proposed rulemaking (ANPRM) soliciting information as EPA considers a future rulemaking to add certain per- and polyfluoroalkyl substances (PFAS) to the list of toxic chemicals subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 6607 of the Pollution Prevention Act (PPA) (more commonly known as the Toxics Release Inventory...