The U.S. Environmental Protection Agency’s (EPA) resources are not expected to be robust. This will translate to further reductions in its operating programs such as the Office of Chemical Safety and Pollution Prevention (OCSPP), and eventually (if not already) will translate into personnel, skills-mix and salary impacts. This will hinder the ability of both OCSPP programs – Office of Pesticide Programs (OPP) and Office of Pollution Prevention and Toxics (OPPT) – to review submissions in...
February 1, 2013
Lynn L. Bergeson, “EPA Releases List of EDSP Universe of Chemicals,” Pollution Engineering, February 1, 2013.
On November 27, 2012, EPA released The EDSP Universe of Chemicals and General Validation Principles, as well as the list of approximately 10,000 chemicals. This article explains the document and its implications....
January 16, 2013
Lynn L. Bergeson, “EPA Releases TSCA Chemical Risk Assessments,” Chemical Processing, January 16, 2013.
The U.S. Environmental Protection Agency (EPA) released on January 4, 2013, the first draft risk assessments developed under the Toxic Substances Control Act (TSCA) Work Plan. This article explains why these assessments are important....
January 4, 2013
Lynn L. Bergeson, “Election Fallout: Regulatory Expectation After 2012 Election,” Pollution Engineering, January 4, 2013.
Since President Obama won on November 6, the forecast for Pollution Engineering readers is a bit clearer. Below are preliminary observations on what lies ahead regarding environmental issues at the legislative and regulatory levels....
January 1, 2013
Lynn L. Bergeson, “One Step Closer: California Proposes Safer Consumer Products Regulations,” Environmental Quality Management, Winter 2012.
The California Department of Toxic Substances Control (CDTSC) is one step closer to implementing the state’s Green Chemistry Initiative (GCI), which directs regulators to evaluate safer alternatives to chemicals that are believed to be toxic. These are not “garden variety” chemical regulations that impose a restriction here or there to prevent a perceived risk. Far from it. These regulations are game-changers. They ultimately will transform the way manufacturers select raw materials and...
December 13, 2012
Lynn L. Bergeson, “EPA Keeps Close Eye on Cadmium,” Chemical Processing, December 13, 2012.
On December 3, 2012, the U.S. Environmental Protection Agency (EPA) continued its use of the Toxic Substances Control Act (TSCA) to regulate products (not just chemicals) in publishing a final rule adding cadmium and cadmium compounds to the TSCA Section 8(d) rule. In so doing, manufacturers and importers of cadmium must submit unpublished health and safety studies to the EPA (including use in materials that have been or are “reasonably likely” to be incorporated into...
Barack Obama won a decisive victory in the presidential election on 6 November and the forecast for the next four years is clearer now than it was pre-election. This article offers some preliminary observations on what lies ahead regarding domestic chemical management issues at the legislative and regulatory levels....
November 5, 2012
Lisa R. Burchi and Lynn L. Bergeson, “Pesticide Data Compensation in the EU and Canada,” Bloomberg BNA Daily Environment Report, November 5, 2012.
The European Union in recent years has promulgated new regulations to set forth the procedures by which pesticides (called biocides and plant protectants in the EU) are registered and how companies can address issues related to the citation and compensation of data submitted that support those pesticide registrations. Canada also recently issued regulations setting forth new requirements on how data used to support a pesticide registration are protected. This article provides a broad overview of...
It is entirely appropriate to consider how REACH may influence reconsideration of the U.S. chemical regulatory environment, and the report provides some critical insights. But REACH is not the only consideration — Canada’s Chemical Management Plan should be considered as well. Further, REACH should be considered from a practitioner’s, not an academic’s, perspective to learn lessons relevant to U.S. chemicals management ...
November 1, 2012
Lynn L. Bergeson, “Proposed PFAS and LCPFAC SNURs,” Pollution Engineering, November 2012.
On August 15, 2012, EPA issued proposed amendments to the significant new use rule (SNUR) for perfluoroalkyl sulfonate (PFAS) chemical substances to add seven PFAS chemical substances that have completed the new chemical review process under the Toxic Substances Control Act (TSCA). EPA has not yet commenced production or import, and to designate (for all listed PFAS chemical substances) “processing” as a significant new use. The agency is also proposing a SNUR for long-chain perfluoroalkyl...