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April 25, 2016

Lisa R. Burchi Presents “Regulatory Updates and Enforcement Trends,” at the 2016 NADC Western Region Meeting

Bergeson & Campbell, P.C.

On April 22, 2016, Lisa R. Burchi, of Counsel with Bergeson & Campbell, P.C., presented “Regulatory Updates and Enforcement Trends,” at the National Association of Chemical Distributors (NACD) Western Region Meeting. Ms. Burchi’s presentation detailed how the Office of Enforcement and Compliance Assurance (OECA) sets priorities and enforcement strategies. OECA identifies compliance monitoring and assurance activities for Toxic Substances Control Act (TSCA) New and Existing Chemicals as well as regulatory compliance and enforcement trends for California Safer Consumer Products Regulations (SCPR) and other state programs. OECA enforces the U.S. Environmental Protection Agency’s (EPA) National Program Managers Guidance (NPMG), specifically where significant environmental risk and non-compliance patterns are known to exist, and where there are important opportunities to improve performance. For many years, including Draft 2016-2017 NPMG, OECA has identified “compliance monitoring and assurance activities for TSCA New and Existing Chemicals” as one of its enforcement priorities.

Ms. Burchi said emerging enforcement focuses anticipated in 2016 include chemical reporting and recordkeeping requirements under the 2016 Chemical Data Reporting (CDR) rule, EPA’s efforts under its TSCA Work Plan to impose restrictions on certain Chemicals of Concern, Significant New Use Rules (SNUR), and state laws.  Ms. Burchi included instructions on how to ensure compliance by auditing inventory listings, and how to check sources to determine reporting requirements. For a copy of Lisa Burchi’s full presentation,