November 5, 2019

EPA Releases Draft Risk Evaluation for NMP, Schedules SACC Review for December

On November 4, 2019, the U.S. Environmental Protection Agency (EPA) announced the availability of the draft risk evaluation for N-methylpyrrolidone (NMP), which includes more than 30 uses of NMP in adhesives, sealants, paints and arts and craft paints, paint and coating removers, adhesive removers, and degreasers. In the draft risk evaluation, EPA has made a preliminary determination that NMP does not present risks to the environment, bystanders, or occupational non-users (ONU)....
November 1, 2019

WEBINAR — Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value, November 13, 2019, 1:00 p.m. – 2:00 p.m. EST

WEBINAR — Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value, November 13, 2019, 1:00 p.m. – 2:00 p.m. EST Bergeson & Campbell, P.C. (B&C®) was pleased to present the complimentary webinar “Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value.” Lynn L. Bergeson, Managing Partner, B&C, and Richard E. Engler, Ph.D.,...
October 31, 2019

EPA Publishes Draft Risk Evaluation for Methylene Chloride

On October 29, 2019, the U.S. Environmental Protection Agency (EPA) published a Federal Register notice announcing the availability of the draft Toxic Substances Control Act (TSCA) risk evaluation for methylene chloride (MC). 84 Fed. Reg. 57866. As reported in our October 25, 2019, memorandum, EPA is submitting the same document to the TSCA Science Advisory Committee on Chemicals (SACC) for peer review. SACC will convene an in-person public meeting to consider and review the...
October 31, 2019

How Do We Know if a New Technology Is Safe?

This week, I moderated a spirited discussion with two members of the B&C team: Sheryl Dolan, a senior regulatory consultant who specializes in agricultural and biocidal chemical product registration and defense, and Dr. Richard Engler, our Director of Chemistry and a 17-year-veteran of EPA.  Both Sheryl and Rich are expert in marshaling new product chemical technologies through the gauntlet of federal, state, and international chemical product approval. Throughout our discussion,...
October 25, 2019

EPA Will Publish Draft Risk Evaluation of Methylene Chloride on October 29

The U.S. Environmental Protection Agency (EPA) will publish a Federal Register notice on October 29, 2019, announcing the availability of and soliciting public comment on the draft Toxic Substances Control Act (TSCA) risk evaluation of methylene chloride (MC). EPA states that it is also submitting the same document to the TSCA Science Advisory Committee on Chemicals (SACC) for peer review and that SACC will convene an in-person public meeting to consider and review the draft risk...
October 19, 2019

Lynn L. Bergeson, “The Growing Influence of Chemical Risk Evaluation on the M&A Market,” Financier Worldwide, October 2019.

In 2018, the global M&A market achieved a transaction volume of $4.1 trillion, the third highest year ever for M&A volumes. Divestitures, spin-offs and split-offs are essential to defining corporate identity, a key shareholder imperative. This brisk pace is expected to continue. Whatever the motivation, M&A activity demands razor-sharp due diligence. The premise of this article is that due diligence often underestimates or, worse, ignores the impact implementation of revisions to the...
October 16, 2019

New York Requires Disclosure of Ingredients in Menstrual Products

On October 11, 2019, New York Governor Andrew M. Cuomo (D) signed legislation (S.2387-B/A.164-B) requiring menstrual product packages or boxes sold in New York State to contain a “plain and conspicuous printed list of all the ingredients in the products.” According to Cuomo’s October 11, 2019, press release, the new law makes New York the first state to require ingredient labels on menstrual products. The legislation will take effect in 180 days, and product manufacturers will...
October 16, 2019

Lynn L. Bergeson, “SEC Proposes Changes To Reporting Rules,” Chemical Processing, October 16, 2019.

Publicly traded companies must disclose certain legal proceedings and risk factors in registration statements and in annual and quarterly reports. These disclosures significantly help investors in assessing the financial integrity of a publicly traded company; formulating a disclosure precisely is critical to compliance, while at the same time accurately capturing the nature and extent of the potential risks. This article summarizes this Securities and Exchange Commission (SEC)...
October 16, 2019

RCRA Improvement Rules: An Update and Discussion

RCRA Improvement Rules: An Update and Discussion Wednesday, October 16, 2019 1:00 p.m. – 2:00 p.m. (EDT) Register Today Overview: On November 28, 2016, the U.S. Environmental Protection Agency (EPA) issued the final “Generator Improvements Rule” under the Resource Conservation and Recovery Act (RCRA). 81 Fed. Reg. 85732. The potential scope of the revised regulatory program is immense — the changes will affect almost 700,000 facilities. The rule is the most comprehensive overhaul...
October 16, 2019

WEBINAR — Value Chain Communications Required under TSCA Consent Orders and SNURs

Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value  Wednesday, November 13, 20191:00 p.m. – 2:00 p.m. (EST) Available On Demand The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) revised the new chemicals review process and existing chemicals risk evaluation scheme.  These changes have triggered the U.S. Environmental Protection Agency’s (EPA) issuance of many more...