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March 29, 2023

Lynn L. Bergeson Quoted by Chemical Watch in Article “Can the US EPA reduce the cost of TSCA risk evaluations?”

Bergeson & Campbell, P.C.

On March 29, 2023, Chemical Watch quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), regarding the U.S. Environmental Protection Agency’s (EPA) plan to to streamline reviews of existing chemicals.

Lynn Bergeson, managing partner of Bergeson & Campbell, says the agency’s reviews “should become more efficient over time”.

There may be challenges in the medium term, as long-time staff retire and the agency onboards and trains new assessors. But Bergeson adds: “Within two to five years, we suspect the staff will be sufficiently stable and experienced to perform reviews efficiently.”

However, much depends on the chemical substance under evaluation.

Data-rich chemicals with many conditions of use (COUs) understandably take the most time, says Bergeson. The wide use of the first ten substances evaluated under TSCA, as well as the ample information on them, for example, may have contributed to the cost of those substances’ evaluations.

By contrast, substances with few COUs, like an industrial intermediate, are more limited in scope and should take much less effort, says Bergeson.


If each presidential election leads to a substantial change in approach, Bergeson says, EPA assessors “will have to relearn continually how to perform assessments”. Settling on a policy that would carry through, irrespective of an administration’s political affiliation, could shield the agency from politics, she says.

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