Memoranda

Bergeson & Campbell, P.C.'s (B&C) thoughts are below on what may be headed our way in 2012 from the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP). The 2012 Presidential Election cycle will influence any activity by either party or the Administration over the next year. We also offer a few thoughts on Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), the Food and Drug Administration (FDA), and Asian...

The U.S. Environmental Protection Agency (EPA) is scheduled to publish on December 28, 2011, proposed significant new use rules (SNUR) for 17 chemical substances that were the subject of premanufacture notices (PMN). According to EPA, 15 of the substances are subject to consent orders under Section 5(e) of the Toxic Substances Control Act (TSCA). Persons who intend to manufacture, import, or process any of the 17 substances for an activity that is designated as a significant new use by the...

On November 23, 2011, the European Union (EU) Council's committee of the permanent representatives of each member state (COREPER) approved the compromise agreement on the proposed EU biocidal products regulation that would repeal and replace the biocidal products Directive 98/8/EC. Under the compromise reached by the EU Council and the European Parliament (EP), biocides would be reviewed regularly, with approvals or renewals valid for a maximum of ten years, and less for "problematic"...

On December 5-6, 2011, the Association of American Pesticide Control Officials (AAPCO)/State Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Issues Research and Evaluation Group (SFIREG) held its semi-annual full committee meeting in U.S. Environmental Protection Agency (EPA) offices in Arlington, Virginia. Through a cooperative agreement in 1978, EPA and AAPCO created SFIREG, an AAPCO committee with EPA funding, to promote information exchange and cooperation between the states and...

On December 5, 2011, the California Department of Toxic Substances Control (DTSC) held a workshop to review DTSC's "informal draft" Safer Consumer Products Regulations (SCPR) released on October 31, 2011. Bergeson & Campbell, P.C.'s (B&C) memoranda providing background information on SCPR are available online. DTSC began by reviewing the elements of the regulation -- the Chemicals of Concern (COC) List; the prioritization of products; the quality assurance of alternative assessments...

The U.S. Environmental Protection Agency (EPA) announced on December 1, 2011, that it granted a conditional registration for a pesticide product containing nanosilver as a new active ingredient. This memorandum provides additional information regarding this momentous regulatory achievement. HeiQ AGS-20 is a silver-based antimicrobial pesticide product that will be incorporated into textiles to suppress the growth of bacteria, which EPA states in its December 1, 2011, Decision Document "cause...

The U.S. Environmental Protection Agency (EPA) announced on December 1, 2011, that it is conditionally registering a pesticide product containing nanosilver as a new active ingredient. HeiQ AGS-20 is a silver-based antimicrobial pesticide product approved for use as a preservative for textiles. The final registration is not yet in the docket. We believe, but cannot confirm, the final registration is largely similar to the draft proposed registration issued last year. As members of the nano...

On November 29, 2011, the National Toxicology Program (NTP) held a listening session on its proposed revisions to the review process for the Report on Carcinogens (RoC). According to NTP, its proposed changes are intended to "enhance transparency and efficiency and to enable the NTP to publish the RoC in a timelier manner. The NTP also seeks to maintain critical elements of the existing process including external scientific and public involvement, scientific rigor, and external peer...

Guidelines for Selecting Product-Related Environmental Sustainability Standards and/or Ecolabeling Programs The American National Standards Institute (ANSI) hosted on November 22, 2011, a webinar delivered by the U.S. Environmental Protection Agency (EPA) and the General Services Administration (GSA) titled Guidelines for Selecting Product-Related Environmental Sustainability Standards and/or Ecolabeling Programs. The webinar provided an update on ongoing federal efforts to develop...

On November 14-15, 2011, the California Department of Toxic Substances Control's (DTSC) Green Ribbon Science Panel (GRSP) met to review DTSC's "informal draft" Safer Consumer Products Regulations (SCPR) released on October 31, 2011. Memoranda providing background information are available online. Information about the meeting can be found online. During the meeting, DTSC provided an explanation for how the regulations were developed and then set forth questions for discussion on three...