March 6, 2012

2011 Predictions for EPA’s Office of Chemical Safety and Pollution Prevention

Bergeson & Campbell, P.C.'s (B&C) thoughts are below on what may be headed our way in 2011 from the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP). In short, the general trends established by the Obama Administration during the past two years are expected to continue notwithstanding the 2010 election results. At the same time, the impact of the election results, notably with the new Republican majority in the House of...
March 2, 2012

EPA Announces TSCA Work Plan Chemicals

On March 1, 2012, the U.S. Environmental Protection Agency (EPA) Office of Pollution Prevention and Toxics (OPPT) announced a work plan of 83 chemicals for further review under the Toxic Substances Control Act (TSCA). EPA identified seven chemicals for risk assessment in 2012, and intends to complete some of these assessments this year and initiate new assessments from the work plan in the coming years. EPA stated that, this Spring, it plans to identify specific chemicals for risk...
February 8, 2012

EPA Announces $1.4 Million Civil Penalty for TSCA Violations

If anyone is thinking big penalties under the Toxic Substances Control Act (TSCA) are a thing of the past, think again. On February 7, 2012, the U.S. Environmental Protection Agency (EPA) announced that Dover Chemical Corporation has agreed to pay a $1.4 million civil penalty for the unauthorized manufacture of chemical substances at facilities in Dover, Ohio, and Hammond, Indiana. The settlement resolves alleged violations of TSCA premanufacture notice (PMN) obligations for the production of...
January 26, 2012

EPA Written Report from January 19, 2012,  Chemical Data Reporting Workshop

On January 19, 2012, Bergeson & Campbell, P.C. (B&C) and B&C Consortia Management, L.L.C. (BCCM) convened a workshop at which invited U.S. Environmental Protection Agency (EPA) staff reviewed case studies on reporting obligations for byproduct and recycled materials under the Chemical Data Reporting (CDR) rule. EPA has recently issued a written report on its responses to the byproduct scenarios BCCM submitted. The written report is posted with EPA's CDR training...
January 25, 2012

Chemical Data Reporting Workshop

On January 19, 2012, Bergeson & Campbell, P.C. (B&C) and B&C Consortia Management, L.L.C. (BCCM) convened a workshop at which invited U.S. Environmental Protection Agency (EPA) staff reviewed case studies on reporting obligations for byproduct and recycled materials under the Chemical Data Reporting rule. For those of you who were unable to listen in, the recorded audio for the workshop is available on B&C's website.
January 24, 2012

OEHHA Issues Final Regulations Concerning Toxics Information Clearinghouse

On January 18, 2012, the California Office of Environmental Health Hazard Assessment (OEHHA) issued final regulations that "specify the hazard traits, toxicological and environmental endpoints and other relevant data to be included" in the Toxics Information Clearinghouse (Clearinghouse) the California Department of Toxic Substances Control (DTSC) will develop. The Clearinghouse will be used, in part, to help DTSC identify chemicals of concern in consumer products as part of its Green Chemistry...
January 19, 2012

Chemical Data Reporting Workshop

On January 19, 2012, Bergeson & Campbell, P.C. (B&C) and B&C Consortia Management, L.L.C. (BCCM) convened a workshop at which invited U.S. Environmental Protection Agency (EPA) staff reviewed case studies on reporting obligations for byproduct and recycled materials under the Chemical Data Reporting rule. The following documents are available on B&C's website: The invitation for the workshop;  EPA's slides; and  The case studies that were compiled by BCCM and that...
January 18, 2012

Representatives Ask EPA to Postpone CDR Deadline

In a January 13, 2012, letter to U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson, Representatives Fred Upton (R-MI), Chair of the House Energy and Commerce Committee, and John Shimkus (R-IL), Chair of the Energy and Commerce Subcommittee on Environment and the Economy, asked EPA to postpone the Chemical Data Reporting (CDR) implementation and compliance deadlines from February 1, 2012, to align it with the future CDR submission periods -- June...
January 10, 2012

GAO Finds Challenges Remain with EPA’s 2009 IRIS Process

On January 9, 2012, the U.S. Government Accountability Office (GAO) released a report entitled Challenges Remain with EPA's Integrated Risk Information System Program, which evaluates the U.S. Environmental Protection Agency's (EPA) progress in completing Integrated Risk Information System (IRIS) assessments under the May 2009 process. EPA revised its IRIS assessment process in May 2009 in response to a March 2008 GAO report on the IRIS program. EPA most recently revised the IRIS process in...
January 4, 2012

Chemical Data Reporting (CDR) Workshop to Review Case Studies on Reporting Byproducts/Recycled Materials

Thursday, January 19, 20129:00 a.m. - 2:00 p.m. (EST) Bergeson & Campbell, P.C. (B&C) and B&C Consortia Management, L.L.C. (BCCM) have organized a workshop to review reporting obligations for byproducts and recycled materials under the Chemical Data Reporting (CDR) rule. B&C previously submitted to the U.S. Environmental Protection Agency (EPA) specific case studies related to byproducts or recycled materials. The case study scenarios were compiled by BCCM and reflect real-life...