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July 25, 2016

Inside EPA Quotes B&C Memorandum In Article “EPA Issues First New Chemical Safety Reviews Under Reformed TSCA Law”

Bergeson & Campbell, P.C.

On July 25, 2016, Inside EPA quoted Bergeson & Campbell P.C.’s (B&C®) memoranda “EPA Releases First Determinations for New Chemicals under New TSCA,” on the U.S. Environmental Protection Agency’s (EPA) use of structure activity relationship (SAR) in premanufacture notice (PMN) reviews.

In a July 22 memo to clients and colleagues, the law firm Bergeson & Campbell also notes that EPA appears to have used structure activity relationship (SAR) modeling in its analyses, though the firm, unlike Denison, applauded the use of these approaches. EPA use of SAR modeling in its PMN review process pre-dates TSCA reform. EPA has used these models for some time in the PMN program, because there is often limited information available about the toxicity and properties of new chemicals.

“It is reassuring that the SAR was used to reach determinations about persistence, bioaccumulation, and hazard potential, including mention of category analysis,” the firm’s memo states. “This suggests that EPA intends to maintain SAR as a basic component in its evaluation of new chemicals consistent with the provisions at Section 4(h) to reduce vertebrate animal testing and to maximize the use of existing hazard information.”