Chemical stakeholders have, over the decades, vigorously debated how best to balance the need for CBI protections with the public’s legitimate and increasing insistence that it has a right-to-know about chemicals to which people may be exposed. Stakeholders in the environmental and public health community seeking greater transparency are challenging the U.S. Environmental Protection Agency’s (EPA) implementation of TSCA’s Section 5 new chemicals program. The case illustrates new...
March 17, 2026
Lynn L. Bergeson, “What New Mexico’s Proposed PFAS Labeling Rule Means for Manufacturers,” Chemical Processing, March 17, 2026.
2026 will be a consequential year for per- and polyfluoroalkyl substances (PFAS) regulation. Safer States released an analysis in February reporting on 2026 state chemical initiatives. According to the analysis, at least 15 major state laws and regulations are expected to take shape, including broad restrictions on PFAS. This column focuses on New Mexico's proposed rule implementing the Per- and Polyfluoroalkyl Substances (PFAS) Protection Act. What makes the New Mexico proposal so interesting...
February 24, 2026
Lynn L. Bergeson, “Is Toxic Substances Control Act Reform in Our Future?,” Chemical Processing, February 24, 2026.
Reform of the Toxic Substances Control Act (TSCA) is a hot topic these days. The release in January of the House Energy and Commerce Subcommittee on Environment’s draft bill titled Discussion Draft of Legislation to Modernize the Toxic Substances Control Act (Discussion Draft) has inspired spirited debate. The Discussion Draft marks a notable milestone in Congress’s increasingly vocal promises to address perceived shortcomings in both the landmark 2016 amendments to TSCA and the U.S....
January 21, 2026
Lynn L. Bergeson, “Chemical Compliance: What to Expect in 2026,” Chemical Processing, January 21, 2026.
Each year, Bergeson & Campbell, P.C., its global consulting affiliate The Acta Group, and consortia management affiliate B&C Consortia Management, L.L.C., prepare a summary overview of things to come in the new year. We are pleased to present our Forecast 2026. Our global team of chemical experts works hard each year to summarize our collective best guess on what to expect in the new year regarding global industrial, agricultural and biocidal chemical regulatory and policy initiatives....
December 12, 2025
Lynn L. Bergeson, “Hallelujah, EPA Proposes to Narrow Scope of TSCA Section 8(a)(7) PFAS Reporting Rule,” Chemical Processing, December 10, 2025.
On Nov. 13, 2025, the U.S. Environmental Protection Agency (EPA) proposed revisions (90 Fed. Reg. 50923) to the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). This column summarizes the proposal and the reasons for it.
November 11, 2025
Lynn L. Bergeson, “Microplastics Regulation Revs Up in 2025, More Action Expected in 2026,” Chemical Processing, November 10, 2025.
State and federal regulatory measures to address microplastics are flourishing. This trend is expected to continue in 2026. Provided in this article is an overview of microplastics regulatory and policy developments from 2025 to date.
October 14, 2025
Lynn L. Bergeson, “Defining Risk: EPA Seeks Major TSCA Chemical Evaluation Reforms,” Chemical Processing, October 13, 2025.
On Sept. 23, 2025, the U.S. Environmental Protection Agency (EPA) proposed highly anticipated amendments to the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA). When conducting a TSCA existing chemical risk evaluation, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or non-risk factors under the conditions of use (COU). As...
September 18, 2025
Lynn L. Bergeson, “Compliance: Microplastics Regulation Surges,” Chemical Processing, September 16, 2025.
This year has seen a significant increase in legislative, regulatory and policy initiatives involving microplastics. This momentum suggests more regulatory activity moving forward for quite some time, although in ways that are not always clear or predictable.
August 20, 2025
Lynn L. Bergeson, “What Does a Much Smaller Office of Research and Development Mean?,” Chemical Processing, August 18, 2025.
On July 18, 2025, the U.S. Environmental Protection Agency (EPA) rolled out the “reorganization plan” for its Office of Research and Development (ORD). The plan’s stated goal is to reduce budget expenditures, improve science, and have EPA’s research activities better support the work of EPA’s media offices. The EPA press release refers to the reorganization effort as a continuation of “comprehensive restructuring” that includes a reduction in force (RIF) for the ORD and a...
July 24, 2025
Lynn L. Bergeson, “Leveraging Chemical Data More Efficiently,” PCB007 Magazine, July 2025.
Some truths transcend politics, one being that chemical data holds enduring value and is becoming increasingly essential. In the United States, regardless of which party federally controls the levers of power, it's clear that chemical manufacturers and their customers must develop and curate robust data portfolios for their chemical inventories. The commercial imperatives driving this are undeniable and gaining traction.