January 14, 2019

NYDEC Delays for Three Months Enforcement of its Household Cleansing Product Information Disclosure Program

On January 9, 2019, the New York Department of Environmental Conservation (NYDEC) announced it was delaying its enforcement of the New York Household Cleansing Product Information Disclosure Program (Disclosure Program) to October 1, 2019. NYDEC’s announcement was published in the Environmental Notice Bulletin. As previously reported, on June 6, 2018, NYDEC released its Disclosure Program setting forth extensive requirements for manufacturers of certain consumer...
January 11, 2019

Bloomberg Environment Features Comments by Kathleen M. Roberts Regarding Delayed CDR Rule

On January 11, 2019, Bloomberg Environment spoke with Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), for the article “Chemical Makers’ Data Duties Delayed by Shutdown.” “Assuming the proposed changes are not major, the delay in releasing the proposed [Chemical Data Reporting] rule is an inconvenience rather than a block impeding chemical manufacturers ability to do business,” said Kathleen M. Roberts, a vice president at...
January 10, 2019

Dis-harmonization” of GHS

This week, I sat down with Karin Baron, a senior regulatory consultant here at Bergeson & Campbell and all around expert on chemical product labeling to discuss recent developments pertinent to the United States Hazard Communication Standard (HCS). These regulatory developments have been proposed to bring the HCS more in line with GHS, the Global Hazard Communication Standard. Karin unpacks this complex but really important area of the law and focuses on the aspirational and important goals...
January 9, 2019

Lynn L. Bergeson, “A Glimpse of Things to Come: OSHA’s Soon to Be Updated Hazard Communication Standard,” Environmental Quality Management, Volume 28, Issue 2, Winter 2018.

In the Trump Administration’s Unified Agenda of Regulatory and Deregulatory Actions (Regulatory Agenda) issued on October 17, 2018, the US Department of Labor’s Occupational Safety and Health Administration (OSHA) published a Proposed Rule Stage item titled, “Update to the Hazard Communication Standard,” RIN 1218-AC93 (OSHA, 2018), and scheduled the Notice of Proposed Rulemaking (NPRM) to be issued by March, 2019. This could be an important regulatory development for all...
January 8, 2019

Forecast for U.S. Federal and International Chemical Regulatory Policy 2019

Click here for a PDF brochure of the memorandum Bergeson & Campbell, P.C. (B&C®) and its consulting affiliate The Acta Group (Acta®) are pleased to offer you our Forecast 2019. In this richly detailed document, the legal, scientific, and regulatory professionals of B&C and Acta distill key trends in U.S. and global chemical law and provide our best informed judgment as to the shape of key developments we are likely to see in the New Year. Our unique business platform and growing...
January 7, 2019

EPA Denies TSCA Section 21 Petition Seeking Increased Asbestos Reporting

On December 21, 2018, the U.S. Environmental Protection Agency (EPA) denied a petition filed under Section 21 of the Toxic Substances Control Act (TSCA) requesting that EPA initiate rulemaking to amend the TSCA Chemical Data Reporting (CDR) rule to increase reporting of asbestos. EPA denied the September 27, 2018, petition on the grounds that the petitioners, the Asbestos Disease Awareness Organization, American Public Health Association, Center for Environmental Health, Environmental...
January 7, 2019

Inside EPA Includes Quotes From James V. Aidala In The Article “Democrats Seek PRIA Passage After EPA Vows To Preserve Pesticide Rules”

On January 7, 2019, Inside EPA featured comments by James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®), regarding new efforts to reauthorize the U.S. Environmental Protection Agency’s (EPA) Pesticide Registration Improvement Act (PRIA) program. EPA's authority to collect fees lapsed Dec. 21 when lawmakers failed to approve legislation funding EPA and other agencies, depriving them of a legislative vehicle to which they could...
January 7, 2019

Bloomberg Environment Features Comments By Lynn L. Bergeson and Richard E. Engler, Ph.D., in the Article “Wheeler Pledges More ‘Sunshine’ on Chemical Oversight”

On January 7, 2019, Bloomberg Environment quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, regarding U.S. Environmental Protection Agency (EPA) Acting Administrator Andrew Wheeler’s pledge to make public more information about chemical safety decisions. Richard Engler, director of chemistry at Bergeson & Campbell PC, described Wheeler’s promises as reflecting “EPA’s...
January 2, 2019

Zameer Qureshi, “Brexit: REACHing Compliance Goals Under Evolving Circumstances,” Elements, the Magazine of Chemicals Northwest, Winter 2018.

Brexit is a moving target from a political viewpoint, but many matters for regulatory compliance and product stewardship teams globally appear clearer than before. This article suggests timely REACH compliance strategies companies should adopt and implement that account for wide-ranging Brexit repercussions.
December 21, 2018

Bloomberg Environment Includes Quotes From Christopher R. Bryant In The Article “2019 Outlook: EPA To Ease Companies’ Coal Ash Disposal Rules”

On December 21, 2018, Bloomberg Environment featured comments by Christopher R. Bryant, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), regarding the U.S. Environmental Protection Agency’s (EPA) plan to update coal ash disposal requirements. The changes are consistent with the agency’s preference for states to take the lead on setting their own disposal requirements, Christopher Bryant, senior regulatory consultant for Bergeson & Campbell PC in...