September 25, 2012

Lynn L. Bergeson, “Source of Minerals Gets New Scrutiny,” Chemical Processing, September 25, 2012.

On August 22, 2012, the Securities and Exchange Commission (SEC) adopted a final rule implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This important and sweeping rule is effective for products manufactured in 2013, and the first annual reports are due May 31, 2014, and on May 31 every year thereafter. It obligates companies using minerals that might have come from conflict zones to disclose their use. Because such minerals...
September 1, 2012

Lynn L. Bergeson, “Old Dogs and New Tricks:  US EPA Gets Creative with TSCA,” Environmental Quality Management, Autumn (Fall) 2012.

The United States Environmental Protection Agency (US EPA) has taken some bold steps recently to strengthen its authority over existing chemicals — using its expansive, but much maligned, authority under the Toxic Substances Control Act (TSCA). TSCA is an old statute, and believed by many to be out of date. But in “repurposing” its interpretation of its TSCA authority, US EPA has confirmed that the statute is more than a paper tiger...
August 1, 2012

Lynn L. Bergeson, “California Aims For Safer Consumer Products,” Chemical Processing, August 2012.

In July, the California Department of Toxic Substances Control (DTSC) released proposed Safer Consumer Products regulations, the newest iteration of the much anticipated regulatory implementation of California’s Green Chemistry Initiative. Below is a summary of the core elements of the proposed regulations — chemicals of concern (COC), priority products (PP), alternative analysis (AA), and regulatory responses....
July 1, 2012

Lynn L. Bergeson, “EPA Releases EDSP Management Plan,” Chemical Processing, July 2012.

The U.S. Environmental Protection Agency (EPA) released on June 28, 2012, an Endocrine Disruptor Screening Program (EDSP) “Comprehensive Management Plan.” While it’s intended for internal use, EPA made the plan available to the public to be consistent with its stated objectives for transparency. The plan and its implications are discussed....
July 1, 2012

Lynn L. Bergeson, “US EPA’s $1.4 Million TSCA Enforcement Action:  Why It Matters,” Environmental Quality Management, Summer 2012.

Enforcement actions under the Toxic Substances Control Act (TSCA) are not all that frequent. When they do occur, however, they tend to be memorable. The most recent example involves an action brought by the United States Environmental Protection Agency (US EPA) against Dover Chemical Corporation. On February 7, 2012, the Agency announced that Dover Chemical had agreed to pay a $1.4 million civil penalty for alleged violations of TSCA premanufacture notice (PMN) obligations....