Lynn L. Bergeson Quoted in Chemical Watch Article “Industry awaits US EPA’s next steps as pause on PIP 3:1 enforcement nears end”
On August 11, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding the possibility that the U.S. Environmental Protection Agency (EPA) will extend compliance dates for Toxic Substances Control Act (TSCA) prohibitions on phenol, isopropylated phosphate (3:1) (PIP (3:1)) before a pause on enforcement is set to expire early next month.
Lynn Bergeson, a partner with Bergeson & Campbell who advises companies and trade associations on TSCA compliance, said the agency is aware of and sensitive to “the logistical, commercial and supply chain consequences” if the deadlines for PIP (3:1) are not extended. “It seems logical and legally appropriate” for the EPA to provide deferred compliance dates for commercial entities that were less aware of the rules, she said.
Many entities failed to appreciate the ubiquity of PIP (3:1), Ms Bergeson said. The plasticiser and flame retardant is often used in electronic wiring, and also is commonly used as an anti-wear or anti-compressibility additive in hydraulic fluid, sealants and adhesives.