July 18, 2023

Lynn L. Bergeson, “TSCA, SNURs, and Plastic Waste-Based Feedstocks,” Chemical Processing, July 18, 2023.

On June 20, 2023, the U.S. Environmental Protection Agency (EPA) proposed significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for 18 chemicals subject to premanufacture notices (PMNs). The rulemaking reflects a level of EPA discomfort with certain new chemicals derived from plastic waste. This article explains the significance of this proposal....
July 3, 2023

Lynn L. Bergeson, “Expanding PFAS liability in the US,” Financier Worldwide, July 2023.

Few words inspire the panic that ‘polyfluoroalkyl substance (PFAS)’ does. Companies producing, processing, distributing and using (whether knowingly or not) these substances must be aware of expanding legal liability and take steps now to minimise risk. This article outlines key US per- and PFAS developments, the legal and commercial implications of these developments, and measures stakeholders should consider taking to limit liability....
June 21, 2023

Richard E. Engler, Ph.D., and Todd J. Stedeford, Ph.D., DABT® , ERT, ATS, “What are the key elements and likely impact of the EPA’s proposed rule for methylene chloride?,” Chemical Watch, June 21, 2023.

On 20 April the US EPA announced a proposed rule under section 6(a) of the Toxic Substances Control Act (TSCA) that would prohibit most uses of methylene chloride and require a workplace chemical protection program (WCPP) for non-prohibited uses. This article will outline the key elements of the EPA’s proposal and discuss the likely impact on industry. This article also looks at what this portends for the agency’s future rulemaking activities on chemical substances...
June 9, 2023

Lynn L. Bergeson, “Toxics Release Inventory Reporting: What is New This Year?,” Chemical Processing, June 9, 2023.

Each year about this time, companies are focused on the deadline to submit Toxics Release Inventory (TRI) data to the U.S. Environmental Protection Agency (EPA). Companies well acquainted with this reporting ritual have established protocols to collect the data to enable timely reporting. With the July 1, 2023, deadline rapidly approaching, there are a few new reporting features of which to be aware. This column briefly summarizes important new elements....
May 5, 2023

Lynn L. Bergeson, “TSCA litigation: The case to watch,” Speciality Chemicals Magazine, May/June 2023.

The implementation of the game-changing 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act, amending the Toxic Substances Control Act (TSCA), is now a hotbed of legal dispute. Lawsuits challenging key aspects of the law’s implementation are piling up. While all are legally noteworthy, one citizen enforcement case in particular merits attention. As discussed below, two recent cases have raised novel issues pertinent to the scope of the U.S. Environmental Protection Agency’s...
May 2, 2023

Lynn L. Bergeson, “EPA Can Lead or Get Out of the Way,” The Environmental Forum, May/June 2023.

A major task we face in achieving circularity is ensuring that policies remain nimble in addressing environmental and public health challenges. Our suite of laws and their regulatory implementation sometimes reflect an unhelpful resistance to circularity, expressed in policies that are indifferent or antithetical to an efficient transition to true resource economy....
April 12, 2023

Lynn L. Bergeson, “Congress Strengthens Cosmetics Regulations,” Chemical Processing, April 12, 2023.

In a somewhat unexpected move, Congress enacted the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) on December 29, 2022, as part of the Omnibus Appropriations Act. MoCRA significantly strengthens the U.S. Food and Drug Administration’s (FDA) authority over cosmetic products. Key provisions are summarized in this article....
March 20, 2023

Lynn L. Bergeson, “Maine Clarifies PFAS Product Reporting Requirements,” Chemical Processing, March 20, 2023.

On Feb. 14, 2023, the Maine Department of Environmental Protection (MDEP) announced a much-anticipated proposed rule intended to clarify the notification requirements and sales prohibitions for products and product components containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS). This reporting requirement has generated attention given its broad scope and “first out of the gate” nature. This article contains a summary of the guidance....
February 15, 2023

Lynn L. Bergeson and L. Claire Hansen, “Toxic Substances Law Creating More Confusion for Legal Teams and Public,” Chemical Processing, February 15, 2023.

This article focuses on one of many abrupt, and in some views, unlawful, EPA policy shifts frustrating lawyers and confusing the public. The EPA moved in 2021 from a “conditions of use” approach to evaluating chemical risk to a “whole chemical” approach. This seemingly modest change is a key reason why lawyers advising chemical stakeholders are struggling and why there may be a lot of TSCA litigation in the EPA’s future....
January 30, 2023

Lynn L. Bergeson, “Risky Business: Deciding Whether Chemicals Pose Risk Is Getting Really Confusing,” American College of Environmental Lawyers (ACOEL) Blog, January 27, 2023.

Chemicals are the foundational origin of just about everything we enjoy and cannot live without. The federal law that authorizes the U.S. Environmental Protection Agency (EPA) to regulate industrial chemical substances is the Toxic Substances Control Act (TSCA), an almost 47-year-old law significantly amended in 2016 by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). Lautenberg’s passage was a bipartisan triumph marking the do-over of a law that many...
January 10, 2023

Lynn L. Bergeson, “Chemical Compliance: FTC To Revise Green Guides, Again,” Chemical Processing, January 10, 2023.

The Federal Trade Commission (FTC) is tinkering with the Guides for the Use of Environmental Marketing Claims (Green Guides). Given the growing appeal of “green claims” for a variety of products, it is fitting the FTC is refining and modernizing the Green Guides to help marketers avoid making environmental marketing claims that are unfair or deceptive under Section 5 of the FTC Act. Importantly, the FTC seeks to update the guides “based on increasing consumer...
December 14, 2022

Lynn L. Bergeson, “Sticker Shock: TSCA Fees Could Soon Be a Lot More Expensive,” Chemical Processing, December 13, 2022.

On Nov. 16, 2022, the U.S. Environmental Protection Agency (EPA) published a supplemental proposal modifying its 2021 proposed rule that would amend the 2018 Toxic Substances Control Act (TSCA) fees rule. The EPA’s assistant administrator warned us to be prepared for sticker shock. The proposed increases are significant. This article discusses what you need to know....
October 25, 2022

Lynn L. Bergeson, “OSHA Considers Revisions to Process Safety Management Standard,” Chemical Processing, October 25, 2022.

In August, the U.S. Occupational Safety and Health Administration (OSHA) announced it is considering revisiting the Process Safety Management (PSM) standard. This column summarizes why OSHA is thinking of amending the standard and what you can do to engage in the process....
October 12, 2022

Lynn L. Bergeson, “Toxics Regulation: A Brave New World Catching Many Off Guard,” PLI Current, Vol. 6 (2022).

Given the passage of time since the Toxic Substances Control Act (TSCA) was enacted in 1976, the public’s growing awareness of the potential for exposure from chemicals in “articles,” or finished goods, during use, and greater focus on the implications of end-of-life product disposal, the U.S. Environmental Protection Agency’s (EPA) regulation of articles under TSCA has shifted significantly. Historically, EPA elected not to regulate articles for the most part. EPA’s more recent...
September 23, 2022

Lynn L. Bergeson, “EPA Targets PFAS Cleanup,” Chemical Processing, September 23, 2022.

Cleanup costs under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) are about to get a lot more expensive. The U.S. Environmental Protection Agency (EPA) announced on September 6, 2022, that it will propose to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), two of the most widely used per- and polyfluoroalkyl substances (PFAS), as hazardous substances under CERCLA. The rulemaking would also require entities immediately to report...
September 15, 2022

Lynn L. Bergeson, “Due diligence in mergers and acquisitions involving chemical products,” Financier Worldwide, October 2022.

The scope of what diligence is due in any corporate transaction has evolved greatly over the past decade, particularly with respect to transactions involving chemical products. Once upon a time, transactional due diligence involving chemical products, whether ‘neat’ (pure) chemicals, formulations or end-use products, typically consisted of a phase I or phase II environmental site assessment (ESA) focusing on identifying contamination derivative of chemical releases into environmental media...
August 22, 2022

Lynn L. Bergeson, “EPA Holds Webinar on PFAS Strategic Roadmap: Research Tools and Resources,” Finishing & Coating, August 22, 2022.

The U.S. Environmental Protection Agency held a webinar on August 17, on the “EPA PFAS Strategic Roadmap: Research Tools and Resources.” The webinar provided a brief overview of EPA’s PFAS Strategic Roadmap and ongoing efforts by EPA’s Office of Research and Development (ORD) to address key per- and polyfluoroalkyl substances (PFAS) research needs for environmental decision-making. ...
August 16, 2022

Lynn L. Bergeson and Richard E. Engler, Ph.D., “Optimizing the Toxic Substances Control Act to Achieve Greener Chemicals,” NR&E, Summer 2022.

The Toxic Substances Control Act (TSCA) offers tremendous unrealized potential to promote the development of more sustainable industrial chemicals. Despite the fact that Congress significantly amended TSCA in 2016 specifically to diminish the human health and environmental footprint of industrial chemicals, the U.S. Environmental Protection Agency (EPA) is interpreting the revised law in ways that ironically discourage the commercialization of new chemicals and reinforce a “new chemical...
August 15, 2022

Lynn L. Bergeson, “EPA Eases TSCA Testing Demands,” Chemical Processing, August 15, 2022.

The U.S. Environmental Protection Agency (EPA) has issued two new documents for recipients of Section 4 test orders under the Toxic Substances Control Act (TSCA). The good news is these documents offer relief to stakeholders who otherwise would be responsible for chemical testing costs for certain chemicals they produced or imported....
August 5, 2022

Lynn L. Bergeson, “EPA Seeks Input From Small Businesses,” Chemical Processing, August 1, 2022.

The U.S. Environmental Protection Agency (EPA) invited on July 6, 2022, small businesses to participate as Small Entity Representatives (SER) for a Small Business Advocacy Review (SBAR) panel. The EPA seeks self-nominations directly from entities that may be subject to the rule requirements; self-nominations were due July 20, 2022. The panel focuses on the agency’s proposed rule to collect data to inform each step of the Toxic Substances Control Act (TSCA) risk evaluation and risk...
July 28, 2022

Lynn L. Bergeson, “How does a recent Supreme Court ruling apply to the EPA’s implementation of TSCA?,” Chemical Watch, July 27, 2022.

Since the US Supreme Court issued its blockbuster ruling in West Virginia v EPA, 597 US _ 2022 WL 2347278 (30 June 2022), many are asking whether the Court’s amplification of the ‘major questions doctrine’ (MQD) might be used to seek to limit the US EPA’s authority in implementing Congress’s 2016 amendments to TSCA, the Frank R Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). Lynn L Bergeson, managing partner of the law firm Bergeson...
June 28, 2022

Lynn L. Bergeson, “Chemical Compliance: Get Ready For Superfund Excise Tax,” Chemical Processing, June 22, 2022.

On November 15, 2021, President Biden signed into law the Infrastructure Investment and Jobs Act (IIJA), reinstating the Superfund excise tax on certain chemical substances under Sections 4661 and 4671 of the Internal Revenue Code (Tax Code). Effective July 1, 2022, the tax many were glad to see expire is back; the first deposit of the tax is due on July 29, 2022. This article discusses the tax and the challenges it poses....
June 21, 2022

Lynn L. Bergeson, “Environmental Justice and Enforcement in America: what investors need to know,” Financier Worldwide, July 2022.

By any standard, federal enforcement of environmental laws in the US has been uneven, to say the least. The prevailing perception is that democrats are ‘greener’ than are republicans when it comes to environmental enforcement. The data is quite scattered, however, and it would seem no party has cornered the environmental protection market. The Trump administration may be the exception that proves the rule. Most would agree civil and criminal enforcement case numbers were significantly...
May 19, 2022

Lynn L. Bergeson, Richard E. Engler, Ph.D., et al, “Compilation Memorandum regarding the GCSE Plastics Reports: France and the United States: Comparative Law Analysis and Recommendations Regarding Plastic Waste,” Global Council for Science and the Environment, May 15, 2022.

In February 2022, France and the United States announced their commitment to protect our shared environment for future generations against the harm resulting plastic pollution.Both nations stated their united recognition of the transboundary impacts of plastic pollution and the importance of mitigating plastic waste at its source. On March 2, 2022, as reported by the 5th UN Environment Assembly (UNAE-5.2) in Nairobi, both France and the United States, along with 173 other...
April 25, 2022

Lynn L. Bergeson, “California Eyes Proposition 65 Modifications,” Chemical Processing, April 24, 2022.

On April 5, 2022, the California Office of Environmental Health Hazard Assessment (OEHHA) issued a notice recommending additional revisions to its proposal to modify Proposition 65 (Prop 65) Article 6 “clear and reasonable warnings” regulations for “short-form” warnings (Notice). OEHHA first proposed to change the short-form warning requirements on January 8, 2021. This column explains the significance of this development....
April 14, 2022

Carla N. Hutton and Karin F Baron, MSPH, “How might EU proposals on harmonised classification and prioritisation of chemicals for classification impact industry?,” Chemical Watch, April 14, 2022.

The Chemicals Strategy for Sustainability, adopted by the European Commission in October 2020, calls on the Commission to ensure that Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation) is the central legislation for hazard classification and allows the Commission to initiate harmonised classifications. This article examines the effect of possible CLP amendments....
February 25, 2022

Lynn L. Bergeson, “Per- And Polyfluoroalkyl Substances (PFAS): One Size Does Not Fit All,” Chemical Processing, February 27, 2022.

Per- and polyfluoroalkyl substances (PFAS) are getting a lot of attention in the United States and globally. Their varied chemical properties make the categorization of “PFAS” into a single category chemically and scientifically questionable. Increasingly, the ability to make distinctions among this large chemical category is challenging, yet failure to do so could be unwise. This article provides information on PFAS, and offers a few suggestions to keep in mind when making business...
February 23, 2022

Lynn L. Bergeson, “PFAS: making sound investment decisions,” Financier Worldwide, March 2022.

The ubiquity of per- and polyfluoroalkyl substances (PFAS) and the manufacturing sector’s decades-long reliance on them to impart functionalities in a dizzying array of products put the investor between the proverbial rock and a hard place. PFAS varied chemical properties make the broad categorisation of ‘PFAS’ into a monolithic category of ‘forever chemicals’ chemically and scientifically questionable. For better or worse, however, that is exactly what is happening today, and...
January 25, 2022

Lynn L. Bergeson, “Isn’t It Ironic?,“American College of Environmental Lawyers (ACOEL) Blog, January 25, 2022.

The Biden Administration’s U.S. Environmental Protection Agency (EPA) is laser focused on achieving several “whole-of-government” priorities: addressing climate change, identifying and giving environmental justice greater consideration in decision-making, and following the science wherever it may lead. Knowing and respecting leadership in the Office of Chemical Safety and Pollution Prevention (OCSPP) tasked with achieving these laudable yet daunting objectives, there is no question the...
January 24, 2022

Lynn L. Bergeson, “Toxic Substances: EPA Targets Asbestos,” Chemical Processing, January 23, 2022.

The Toxic Substances Control Act (TSCA) has long been considered the “poster child” of failure as a chemical control law when it comes to asbestos regulation. The U.S. Environmental Protection Agency (EPA) in its latest approach to regulating “legacy” uses may well invite heightened scrutiny. The EPA announced in December the availability of the Draft Scope of the Risk Evaluation for Asbestos, Part 2. In it, the agency will evaluate conditions of use of asbestos...
December 14, 2021

Lynn L. Bergeson, “Environmental Protection: Infrastructure Law Benefits Chemical Industry,” Chemical Processing, December 14, 2021.

On November 15, 2021, President Biden signed into law the Infrastructure Investment and Jobs Act (H.R. 3684). The House passed the bill on November 5, 2021, by a vote of 228 to 206, and the Senate passed the bill on August 10, 2021, by a vote of 69 to 30. The bill provides a $1.2-trillion infusion of cash into the economy and contains many provisions important to the chemical processing sector. Highlighted below are some...
December 9, 2021

Lynn L. Bergeson, “Straddling digital and environmental goals: tips for investors,” Financier Worldwide, January 2022.

The environmental impacts of the digital economy are increasingly the focus of attention and concern. There is no question the demand for electricity, water and land have increased sharply in response to the growth in digital activity. Identifying, quantifying and mitigating environmental and ecological impacts are core to value creation, and investors must be mindful of how a company is positioned to create value while avoiding public rebuke for neglecting to account for the environmental...
November 22, 2021

Lynn L. Bergeson, “Supply-Chain Aid — EPA Proposes PIP 3:1 Compliance Extension,” Chemical Processing, November 22, 2021.

The U.S. Environmental Protection Agency (EPA) announced on October 21 that it intends to move further back the compliance dates related to articles containing phenol, isopropylated phosphate (3:1) (PIP (3:1)) to ensure supply chains for key consumer and commercial goods are not disrupted. The agency proposed extending the compliance date until October 31, 2024, along with the associated recordkeeping requirements for manufacturers, processors and distributors of PIP (3:1)-containing articles....
October 18, 2021

Lynn L. Bergeson, “Is Extended Producer Responsibility On The Rise For Packaging?,” Chemical Processing, October 18, 2021.

On July 13, 2021, Maine became the first state to enact Extended Producer Responsibility (EPR) legislation for packaging. On August 6, 2021, Oregon followed, enacting a similar EPR law applicable to packaging. Other states are poised to pass similar legislation. This article discusses the concept of EPR and summarizes the state legislation....
October 1, 2021

Lynn L. Bergeson, “Extended producer responsibility for packaging: and so it begins in the US,” Financier Worldwide, October 2021.

On 13 July 2021, Maine became the first state in the US to enact extended producer responsibility (EPR) legislation for packaging. Quickly thereafter, on 6 August, Oregon became the second state to enact a similar EPR law applicable to packaging. Other states are poised to enact similar legislation, following trends more mature in the European Union (EU) and elsewhere around the world....
September 15, 2021

Lynn L. Bergeson, “EPA Goes Back To The Drawing Board On Toxic Substances,” Chemical Processing, September 15, 2021.

The implementation of the Toxic Substances Control Act (TSCA) provisions relating to regulating persistent, bioaccumulative and toxic (PBT) chemicals has been anything but smooth. On September 3, 2021, the Environmental Protection Agency (EPA) announced it intends to initiate new PBT rulemaking and anticipates proposing new rules for five PBT chemicals subject to final risk management rules under TSCA Section 6(h). Additionally, and happily, the agency extended the compliance dates for the...
August 24, 2021

Lynn L. Bergeson, “Is FDA Food Safety Revision in Our Future?,” Chemical Processing, August 24, 2021.

Food safety comes in many forms. Years ago, Congress passed the Food Quality Protection Act, amending the nation’s pesticide law to ensure a safer, more reliable, food supply. Consumer groups have urged Congress for years to modernize the nation’s food chemical law, the Federal Food, Drug, and Cosmetic Act (FFDCA), to address often-stated concerns with chemicals in food. Thus far, those concerns remain largely unaddressed by any legislative effort. Things may be changing. On July...
August 2, 2021

Carla N. Hutton and Karin F. Baron, MSPH, “Expert Briefing: What could the European Commission’s plan to strengthen CLP mean for industry?,”Chemical Watch, August 2, 2021.

To help achieve the ambitious goals of the European Green Deal, the European Commission adopted the chemicals strategy for sustainability in October 2020. The strategy suggests that the Commission can address pressing human health and environmental concerns by reinforcing Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures – one of the EU’s cornerstones for regulating chemicals....
July 19, 2021

Lynn L. Bergeson, “PFAS: Is Anything Not Reportable?,” Chemical Processing, July 19, 2021.

The U.S. Environmental Protection Agency (EPA) announced on June 10, 2021, three actions intended to protect communities from per- and polyfluoroalkyl substances (PFAS), as covered in July’s column “EPA Announces Blockbuster PFAS Actions.” This column focuses on one of them: an ambitious proposal intended to obtain comprehensive data on more than 1,000 PFAS manufactured in or imported into the United States. As discussed in this article, the proposal’s scope is enormous....
July 13, 2021

Lynn L. Bergeson, “Avoiding costly supply chain disruption: a cautionary tale,” Financier Worldwide, July 2021.

By any independent standard, the US electronics industry is huge – it was worth over $300bn in 2019 – and growing annually. Would it surprise you to know that as big, essential and powerful as it is, a single rule issued in January of this year by the US Environmental Protection Agency (EPA) nearly brought this sector to a halt? To this day, the rule is causing extraordinary disruption as electric and electronic device manufacturers,...
June 1, 2021

Lynn L. Bergeson, “The essential role of evolving technologies in securing a safe and sustainable food supply,” Agricultural Law Section of the International Bar Association, June 1, 2021.

Emerging tools enabled by nanotechnology, synthetic biology, and other innovative technologies are today increasingly supplementing the ploughs and tractors so emblematic of the agricultural community of the past. These precision farming tools are ensuring a sustainable food supply otherwise threatened by climate change and population growth, among other global challenges, while diminishing worldwide greenhouse gas emissions. Genetically modified E coli is being used to produce...
May 26, 2021

Lynn L. Bergeson, “TSCA: A change of course,” Specialty Chemicals Magazine , May/June 2021.

Just as the industrial chemical community was getting into a predictable, somewhat comfortable groove regarding commercializing new chemicals under the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) decided to blow up the process. With it went any hope for business certainty in this highly volatile regulatory area.  While new administrations are entitled to shape policies to align with their agendas, the Biden Administration’s decision to rescind...
May 17, 2021

Lynn L. Bergeson, “EPA Expands TRI Reporting Rules,” Chemical Processing, May 17, 2021.

The U.S. Environmental Protection Agency (EPA) announced on April 29, 2021, that it will be “taking important steps under the Toxics Release Inventory (TRI) to advance environmental justice, improve transparency, and increase access to environmental information.” The EPA plans to expand the scope of TRI reporting requirements to cover additional chemicals and facilities, including those not currently reporting ethylene oxide (EtO) releases. The agency also announced enhancements to its TRI...
May 1, 2021

Lynn L. Bergeson, “The TSCA under the Biden administration: what to expect,” Environmental Law & Management, Volume 31, Issue 6, 2019.

The U.S. Environmental Protection Agency (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP) will be busy in 2021. Implementation of the 2016 amendments to the Toxic Substances Control Act (TSCA) will continue to dominate the Office of Pollution Prevention and Toxics (OPPT). In 2021, the EPA will need to complete outstanding risk evaluators of the ‘first 10′ chemicals and begin developing proposals for the section 6 risk management rules necessitated by the risk...
April 21, 2021

Lynn L. Bergeson, “Don’t Ignore Game-Changing EU Environmental Initiatives,” Bloomberg Law Insights, April 21, 2021.

Two developments in the European Union in 2020 involving chemical regulations will almost certainly impact U.S. chemical stakeholders, according to Lynn L. Bergeson, managing partner of Bergeson & Campbell P.C. One initiative restricts certain chemicals in order to comply with the European Green Deal, while the other amends chemical disclosure requirements, she explains....
April 21, 2021

Lynn L. Bergeson, “EPA Eyes Stricter Phosphogypsum Rule,” Chemical Processing, April 21, 2021.

In early April, a Florida pond that sits atop phosphogypsum tailings sprung a leak. State authorities scrambled to keep the pond from collapsing and flooding the surrounding area with millions of gallons of contaminated water. This situation likely wasn’t top of mind on February 8, 2021, when a group of environmental protection advocates prepared and submitted to the U.S. Environmental Protection Agency (EPA) a petition under Section 21 of the Toxic Substances Control Act (TSCA)....
April 19, 2021

Lynn L. Bergeson, “EC Scientific Committee’s Preliminary Opinions for Certain Gold and Platinum Nanomaterials Open for Comment,” Nanotechnology Now, April 19, 2021.

On April 16, 2021, the European Commission (EC) Scientific Committee on Consumer Safety (SCCS) posted two preliminary opinions for comment: Opinion on Gold (nano), Colloidal Gold (nano), Gold Thioethylamino Hyaluronic Acid (nano) and Acetyl heptapeptide-9 Colloidal gold (nano) and Opinion on Platinum (nano), Colloidal Platinum (nano) and Acetyl tetrapeptide-17 Colloidal Platinum (nano)....