Download PDF
August 18, 2022

Is There A New Chemical Bias? — A Conversation with Richard E. Engler, Ph.D.

Bergeson & Campbell, P.C.

Download transcript.

This week I sat down with Dr. Richard E. Engler, B&C’s and The Acta Group’s (our consulting affiliate) Director of Chemistry, to discuss the new chemical bias. Our listeners know that Rich Engler has worked for decades reviewing Premanufacture Notifications submitted under the Toxic Substances Control Act (TSCA). PMNs are applications to manufacture or import chemical substances that are not listed on the TSCA Inventory and thus are considered “new.” Much has changed in terms of the new chemical review process since Congress revised TSCA six years ago. As we discuss in our podcast, however, one thing has not changed: the new chemical bias is as potent today as it was before Lautenberg was enacted in 2016. Rich and I discuss the new chemical bias, explain why it continues to confound chemical innovators, and what is being done to eliminate the bias and level the playing field.

ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.