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September 1, 2012

Lynn L. Bergeson, “Old Dogs and New Tricks:  US EPA Gets Creative with TSCA,” Environmental Quality Management, Autumn (Fall) 2012.

Bergeson & Campbell, P.C.

The United States Environmental Protection Agency (US EPA) has taken some bold steps recently to strengthen its authority over existing chemicals — using its expansive, but much maligned, authority under the Toxic Substances Control Act (TSCA). TSCA is an old statute, and believed by many to be out of date. But in “repurposing” its interpretation of its TSCA authority, US EPA has confirmed that the statute is more than a paper tiger