April 17, 2020

EPA Holds Calls on Plan to Reduce Burden for Certain Stakeholders Subject to TSCA Fees Rule Requirements for EPA-Initiated Risk Evaluations

On April 16, 2020, the U.S. Environmental Protection Agency (EPA) hosted a call on its recently announced plan to reduce the burden for certain stakeholders subject to the Toxic Substances Control Act (TSCA) fees rule requirements for EPA-initiated risk evaluations.  The call covered: EPA announced on March 25, 2020, that plans to initiate a new rulemaking process to consider proposing exemptions to the current rule’s self-identification requirements associated with...
April 14, 2020

EPA Publishes Updated Data on TSCA CBI Reviews

 The U.S. Environmental Protection Agency (EPA) published on August 11, 2020, its quarterly update of the Toxic Substances Control Act (TSCA) confidential business information (CBI) review statistics.  These data summarize the number of CBI cases under review and results of completed reviews through June 15, 2020: CBI Review Statistics (cases received between June 22, 2016 and June 15, 2020) Cases in which the specific chemical identity is subject to CBI review 3,326 Cases in...
April 9, 2020

EPA Will Host April 16 Call on TSCA Fees for EPA-Initiated Risk Evaluations

The U.S. Environmental Protection Agency (EPA) will hold a call on April 16, 2020, from 1:00 p.m. to 2:00 p.m. (EDT) on its recently announced plan to reduce burden for certain stakeholders subject to the Toxic Substances Control Act (TSCA) fees rule requirements for EPA-initiated risk evaluations.  The call will cover: EPA asks stakeholders to submit questions by April 14, 2020, to Ben Dyson, dyson.benjamin@epa.gov, and EPA will address them during the call. ...
April 8, 2020

EPA Receives Manufacturer Request for Risk Evaluation of D4

The U.S. Environmental Protection Agency (EPA) announced on April 8, 2020, that it received a complete manufacturer request for EPA to conduct a risk evaluation of octamethylcyclotetrasiloxane (D4) from Dow Silicones Corporation, Elkem Silicones USA Corporation, Evonik Corporation, Momentive Performance Materials, Shin-Etsu Silicones of America, Inc., and Wacker Chemical Corporation through the American Chemistry Council’s Silicones Environmental, Health, and Safety Center.  EPA states that...
April 7, 2020

Comments on TSCA Collaborative Research Program to Support New Chemicals Due May 10, 2022

The U.S. Environmental Protection Agency (EPA) has placed a March 29, 2022, memorandum correcting the deadline for public comment on the Toxic Substances Control Act (TSCA) Collaborative Research Program to Support New Chemicals. The memorandum states that EPA is clarifying the deadline because the February 25, 2022, Federal Register notice erroneously referenced two different dates. The 60-day comment period on the supporting technical document began when EPA added the document to the...
April 7, 2020

EPA Releases Draft Scope Documents for Public Comment

The U.S. Environmental Protection Agency (EPA) announced on April 6, 2020, that the first set of draft scope documents for the next group of chemicals undergoing risk evaluation under the Toxic Substances Control Act (TSCA) is available for comment.  As reported in our December 20, 2019, memorandum, EPA designated these chemicals as a high priority for risk evaluation in December 2019.  According to EPA, seeking public input on the conditions of use to be included in...
April 3, 2020

EPA Letter to Congress “Correct[s] the Record on the Temporary Enforcement Policy”

The U.S. Environmental Protection Agency (EPA) announced on April 2, 2020, that it sent a letter to all members of Congress to correct the record on its temporary policy regarding enforcement of environmental legal obligations during the COVID-19 pandemic.  EPA states that “[a]s should be apparent to anyone who reads the policy, allegations that EPA ‘will cease all enforcement actions during the coronavirus pandemic’ and that the temporary policy...
April 1, 2020

Acta Group Launches CDR Cross-Check™ To Assist Companies in Identifying Chemical Data Reporting Requirements

The Acta Group (Acta®) announced today the launch of CDR Cross-Check™, an ingenious yet simple tool developed and offered by Acta to assist companies in preparing for the 2020 Chemical Data Reporting (CDR) required by the U.S. Environmental Protection Agency (EPA). CDR Cross-Check utilizes the most recent CDR listing information publicly available provided by EPA (currently, 2016 lists) to identify whether all or some of a company’s inventory of chemical substances are subject to CDR...
April 1, 2020

EPA Publishes Draft Risk Evaluation of Asbestos

The U.S. Environmental Protection Agency (EPA) published the draft risk evaluation of asbestos on March 30, 2020.  EPA reviewed a suite of potential asbestos exposures and made the following initial determinations on risk: EPA states that these initial determinations are based on a draft risk evaluation of the reasonably available information and are not final determinations on whether asbestos presents unreasonable risks under the conditions of use.  EPA will use feedback...
March 31, 2020

EPA Publishes 2020 Mercury Inventory Report

On March 30, 2020, the U.S. Environmental Protection Agency (EPA) published the 2020 Mercury Inventory Report on the supply, use, and trade of mercury in the United States.  The report presents aggregated data submitted on imported mercury, mercury manufactured in the United States, imported mercury-added products, mercury-added products made in the United States, and mercury used in manufacturing processes.  The inventory report also provides a broad view of U.S. mercury...
March 27, 2020

EPA Announces Temporary Enforcement Discretion Policy

The U.S. Environmental Protection Agency (EPA) announced on March 26, 2020, a temporary policy regarding enforcement of environmental legal obligations during the COVID-19 pandemic.  EPA states that its temporary enforcement discretion policy applies to civil violations during the COVID-19 outbreak.  The policy addresses different categories of noncompliance differently.  For example, according to EPA, it “does not expect to seek penalties for noncompliance...
March 25, 2020

Yvette T. Collazo Will Be New Director of EPA’s Office of Pollution Prevention and Toxics

Effective March 29, 2020, Yvette T. Collazo will be the new Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT).  Ms. Collazo previously worked for the U.S. Department of Energy (DOE), where she led activities related to federal contracts and agreements of more than $250 million for the cleanup of radiological, industrial, and groundwater hazards resulting from decades of nuclear material production at DOE’s Savannah River...
March 25, 2020

Yvette T. Collazo Will Be New Director of EPA’s Office of Pollution Prevention and Toxics

Effective March 29, 2020, Yvette T. Collazo will be the new Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT).  Ms. Collazo previously worked for the U.S. Department of Energy (DOE), where she led activities related to federal contracts and agreements of more than $250 million for the cleanup of radiological, industrial, and groundwater hazards resulting from decades of nuclear material production at DOE’s Savannah River...
March 20, 2020

TSCA SACC Meeting on TCE Will Be Virtual Meeting

In a Federal Register notice published on March 20, 2020, the U.S. Environmental Protection Agency (EPA) announced that the March 24-26, 2020, Toxic Substances Control Act (TSCA) Science Advisory Committee on Chemicals (SACC) meeting to review the draft risk evaluation for trichloroethylene (TCE) is being changed to a virtual public meeting.  85 Fed. Reg. 16096.  Participation will be by telephone and webcast only.  EPA states the meeting times and...
March 18, 2020

All Things Chemical™ TSCA Update — A Conversation with Richard E. Engler, Ph.D.

Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), sat down with Dr. Richard Engler, Director of Chemistry at B&C, to bring 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...
March 10, 2020

EPA Announces Grant Opportunity Supporting Innovative Solutions for Reducing Pollution, Including in the Chemical Manufacturing, Processing, and Formulation Sector

On March 5, 2020, the U.S. Environmental Protection Agency (EPA) announced that it is seeking grant applications through the Source Reduction Assistance Grant Program from states, federally recognized tribes, universities, local governments, and other groups to support innovative solutions for source reduction or pollution prevention (P2) through research, education, training, or certain other methods.  EPA notes that as it highlights chemical safety during the month of March, “these...
March 9, 2020

EPA Adds Two Microorganisms to List of Microorganisms Eligible for Exemption from Certain TSCA Reporting Requirements

On March 5, 2020, the U.S. Environmental Protection Agency (EPA) announced that it issued a final rule to add two strains of microorganisms to the list of microorganisms eligible for an exemption from certain reporting requirements under the Toxic Substances Control Act (TSCA).  EPA states that manufacturers of new intergeneric Trichoderma reesei (strain QM6a) and Bacillus amyloliquefaciens (subspecies amyloliquefaciens) may now be eligible to undergo a streamlined review process under...
March 9, 2020

EPA Extends Deadline to Self-Identify as a Manufacturer or Importer of a High-Priority Chemical to May 27

On March 9, 2020, the U.S. Environmental Protection Agency (EPA) announced that it has extended the deadline to self-identify as a manufacturer or importer of a high-priority chemical to May 27, 2020.  EPA states that it is working to address issues identified with implementation of the Toxic Substances Control Act (TSCA) Fees Rule and EPA-initiated risk evaluations.  EPA “is actively seeking ways to address the many implementation impracticalities that have been...
March 6, 2020

Lynn L. Bergeson and EPA Assistant Administrator Alexandra Dapolito Dunn Discuss What to Expect from New TSCA in 2020 as Chemical Risk Evaluations Ramp Up

On March 2, 2020, at ChemCon The Americas 2020 in Philadelphia, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Alexandra Dapolito Dunn, Assistant Administrator, EPA Office of Chemical Safety and Pollution Prevention, sat down with Tjeerd Bokhout to discuss the implementation of Lautenberg and what can be expected through 2020.  Ms. Dunn started off the discussion, noting that EPA is “getting our sea legs under us; we spent the first...
March 5, 2020

Comments on Proposed Supplemental SNUR on LCPFAC Chemical Substances Due April 17

On March 3, 2020, the U.S. Environmental Protection Agency (EPA) published in the Federal Register a proposed supplemental significant new use rule (SNUR) issued under Section 5(a)(2) of the Toxic Substances Control Act (TSCA) for long-chain perfluoroalkyl carboxylate (LCPFAC) chemical substances to make inapplicable the exemption for persons who import a subset of LCPFAC chemical substances as part of surface coatings on articles.  85 Fed. Reg. 12479.  Under the...