Memoranda

Today the U.S. Environmental Protection Agency (EPA) published a Federal Register notice announcing the availability of, and seeking public comment on, a draft Pesticide Registration (PR) Notice entitled "False or Misleading Pesticide Product Brand Names." According to EPA, the draft PR Notice is intended to provide guidance to applicants, registrants, and distributors concerning pesticide product brand names that may be false or misleading, either by themselves or in association with...

Today the U.S. Environmental Protection Agency (EPA) issued what it describes as a "common sense" approach to addressing greenhouse gas (GHG) emissions from stationary sources under the Clean Air Act (CAA) by phasing-in the deadlines by which facilities must obtain permits for GHG emissions. Specifically, this controversial final rule sets thresholds for GHG emissions that define when permits under the New Source Review (NSR) Prevention of Significant Deterioration (PSD) and Title V Operating...

Thank you for participating in Bergeson & Campbell, P.C.'s webinar on TSCA Reform on Monday, May 10, 2010. We are delighted that you were able to participate, and hope that you found the information and format useful and convenient. Apropos of our recent webinar, we thought we would use this occasion to share Charlie Auer's response to a recent blog posting by Dr. Richard Denison regarding the reasons why Charlie believes some aspects of the current legislative initiatives to amend TSCA may...

The Sustainability and Green Procurement Advisory Council (Advisory Council) of the New York Interagency Committee on Sustainability and Green Procurement (Interagency Committee) is in the process of drafting recommendations for inclusion in the annual report required under Governor David Paterson's 2008 Executive Order (EO) directing state agencies, public authorities, and public benefit corporations to buy environmentally friendly products. In September 2009, the Advisory Council voted 9-1 to...

Monday, May 10, 2010 11:00 a.m. - 1:00 p.m. (EDT) Bergeson & Campbell, P.C. (B&C) is hosting a free webinar on TSCA Reform Legislative Initiatives on May 10, 2010. On April 15, 2010, Senator Frank R. Lautenberg (D-NJ) released the text of the Safe Chemicals Act of 2010, S. 3209 (SCA), which is intended to address the "core failings" of TSCA. Also on April 15, 2010, Representatives Bobby Rush (D-IL), Chairman of the Subcommittee on Commerce, Trade, and Consumer Protection, and Henry...

At yesterday's U.S. Environmental Protection Agency's (EPA) Pesticide Program Dialogue Committee (PPDC) meeting, William Jordan, Senior Policy Advisor, Office of Pesticide Programs (OPP), presented slides regarding nanotechnology and pesticides. Jordan briefly described how OPP is defining nanoscale materials and how the technology is being applied to the field of pesticides. His presentation described OPP's recent consultation with EPA's Scientific Advisory Panel (SAP) concerning nanosilver and...

Bergeson & Campbell. P.C. is pleased to provide the summary and comparison of the Toxic Substances Control Act (TSCA) reform measures recently circulated and invites you to participate in a webinar on Monday, May 10, 2010, at 11:00 a.m. - 1:00 p.m. (EDT). Details regarding the webinar are available here. On April 15, 2010, Senator Frank R. Lautenberg (D-NJ) released the text of the Safe Chemicals Act of 2010, S. 3209 (SCA), which is intended to address the "core failings" of TSCA....

On April 16, 2010, the European Chemicals Agency (ECHA) published a list of substances that companies intend to register under the European Union's (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation by the November 30, 2010, deadline. The list is based on feedback received from companies and registrations already submitted via the authorized channels. One reason that this exercise is likely being undertaken now by ECHA is to enable ECHA to identify which...

Today Senator Frank R. Lautenberg (D-NJ) released the text of the Safe Chemicals Act of 2010, which is intended to address the “core failings” of TSCA.  Representatives Bobby Rush (D-IL) and Henry Waxman (D-CA) released a discussion draft of their legislation, the Toxics Chemicals Safety Act of 2010, and announced an aggressive schedule that seeks to complete action by “mid-summer.” Lautenberg’s Safe Chemicals Act would: Ensure EPA will have information on chemical hazards, uses,...

The U.S. Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) on April 5, 2010, issued an Advance Notice of Proposed Rulemaking (ANPRM) stating that it is considering revising the hazardous materials regulations (HMRs) governing the transportation of combustible materials. 75 Fed. Reg. 17111. Specifically, PHMSA is seeking to harmonize the domestic regulations applicable to the transportation of combustible liquids with international...