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February 22, 2024

Lynn L. Bergeson and Richard E. Engler, Ph.D. Quoted in Chemical Watch Article “TSCA new chemical submissions could surge ahead of fees hike”

Bergeson & Campbell, P.C.

On February 21, 2024, comments by Lynn L. Bergeson and Richard E. Engler, Ph.D. were featured in Chemical Watch’s article on a recently published update to the Toxic Substances Control Act (TSCA) fees rule.

Richard Engler, director of chemistry with law firm Bergeson & Campbell, said he expects a surge, but is uncertain if there will be an overall increase in submissions or just an accelerated timeline for companies looking to get their notices in before the fee increase.

The former would likely worsen the backlog of reviews, while the latter would have a “lesser effect”, Dr Engler said.


Regardless of the programme’s climate, companies should stay focused on submitting robust notifications, according to Lynn Bergeson, managing partner at Bergeson & Campbell.

“Any hastily prepared submission is a mistake, and the submission should not be driven by the increased fee but rather recognition that the application is thoughtful, data sufficient and well done”, she said.

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