Monthly Federal Developments Memorandum

ABA And B&C Announce Release Of Chemical Product Law and Supply Chain Stewardship Book: Chemical Product Law and Supply Chain Stewardship, edited by Lynn L. Bergeson and published by the American Bar Association (ABA), provides a road map to navigate efficiently the transformational changes in chemical product law, identifies the practical business and product stewardship implications of the new normal in product regulation, and explains the urgent need for supply chain awareness so that the...

2025 Forecast For U.S. Federal And International Chemical Regulatory Policy: On January 6, 2025, Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) published the “Forecast for U.S. Federal and International Chemical Regulatory Policy 2025.” This carefully curated document represents our seasoned team’s collective take on what to expect regarding global industrial, agricultural, and biocidal chemical initiatives in the New...

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends. We wish you and your family a safe and healthy New Year. As we have for many years, the firm has made a contribution to the House of Ruth, a shelter for battered women and their children, in lieu of gifts to our clients, and on our clients’ behalf. Register Now For “What to Expect in Chemicals Policy and Regulation and...

TSCA/FIFRA/TRI EPA Proposes To Add 16 PFAS And 15 PFAS Categories To The TRI List Of Chemicals: The U.S. Environmental Protection Agency (EPA) proposed on October 8, 2024, to add 16 individual per- and polyfluoroalkyl substances (PFAS) and 15 PFAS categories representing more than 100 individual PFAS to the Toxics Release Inventory (TRI) list of toxic chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA)...

TSCA/FIFRA/TRI White House OSTP Releases PFAS Federal R&D Strategic Plan:The White House Office of Science and Technology Policy (OSTP) announced on September 3, 2024, the release of its Per- and Polyfluoroalkyl Substances (PFAS) Federal Research and Development Strategic Plan (Strategic Plan). Prepared by the Joint Subcommittee on Environment, Innovation, and Public Health PFAS Strategy Team (PFAS ST) of the National Science and Technology Council, the Strategic Plan provides a federal...

TSCA/FIFRA/TRI EPA Updates Safer Choice And DfE Standard: The U.S. Environmental Protection Agency (EPA) announced on August 8, 2024, the availability of the final updated Safer Choice and Design for the Environment (DfE) Standard (the Standard). 89 Fed. Reg. 64915. According to EPA, the update includes a name change to the title of the Standard, a revision to the packaging criteria, a new certification for cleaning service providers, a new provision allowing for preterm partnership...

TSCA/FIFRA/TRI EPA Releases Draft Risk Evaluation For 1,1-Dichloroethane And Draft Hazard Assessment Of 1,2-Dichloroethane For Public Comment And Peer Review: On July 2, 2024, the U.S. Environmental Protection Agency (EPA) announced the release of the draft risk evaluation for 1,1-dichloroethane (1,1-DCE) and the draft human health hazard assessment supporting the draft risk evaluation for 1,2-dichloroethane (1,2-DCE, also known as ethylene dichloride) prepared under the Toxic Substances Control...

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TSCA/FIFRA/TRI                                                                                                                           EPA Announces New Resource Portal And Reporting Tool Improvements Before CDR Reporting Begins On June 1, 2024: On May 16, 2024, the U.S. Environmental Protection Agency (EPA) announced the creation of CDR GuideME, a new resource portal, and...

TSCA/FIFRA/TRI                                                                                                                           EPA Issues Asbestos Part 2 Draft Risk Evaluation, Preliminarily Determines That Asbestos Poses Unreasonable Risk To Human Health: On April 16, 2024, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested...

TSCA/FIFRA/TRI EPA Seeks Comment On Proposed Settlement Agreement To Conclude A TSCA Rulemaking Regulating Lead Wheel Weights, Publishes ANPRM Regarding Lead Wheel Weights: On March 13, 2024, the U.S. Environmental Protection Agency (EPA) published notice of a proposed settlement agreement to address a petition for writ of mandamus filed by the Ecology Center, the Center for Environmental Health, United Parents Against Lead & Other Environmental Hazards, and the Sierra Club in the United...

TSCA/FIFRA/TRI EPA Extends Submission Deadline For Polymer Exemption Reports And Accompanying Claims: The U.S. Environmental Protection Agency (EPA) published a final rule on February 16, 2024, amending the Toxic Substances Control Act (TSCA) regulations for polymers manufactured under the terms of the polymer exemption by extending the submission deadline for reporting. 89 Fed. Reg. 12248. EPA notes that the regulations require that manufacturers (includes importers) of polymers manufactured...

TSCA/FIFRA/TRI                                                                                                                           EPA Announces Automatic Addition Of Seven Additional PFAS To TRI List Of Chemicals: The U.S. Environmental Protection Agency (EPA) announced on January 9, 2024, the automatic addition of seven per- and polyfluoroalkyl substances (PFAS) to...

TSCA/FIFRA/TRI EPA Publishes Final SNURs On Certain Chemical Substances: The U.S. Environmental Protection Agency (EPA) published final significant new use rules (SNUR) on December 18, 2023, for certain chemical substances that were the subject of premanufacture notices (PMN) and are also subject to an Order issued by EPA pursuant to the Toxic Substances Control Act (TSCA). 88 Fed. Reg. 87346. The SNURs require persons who intend to manufacture (defined by statute to include import) or...

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends. We wish you and your family a safe and healthy New Year. As we have for many years, the firm has made a contribution to the House of Ruth, a shelter for battered women and their children, in lieu of gifts to our clients, and on our clients’ behalf....

TSCA/FIFRA/TRI EPA Seeks Public Comment On Whether To Limit The Scope Of The Treated Article Exemption: The U.S. Environmental Protection Agency (EPA) published an advanced notice of proposed rulemaking (ANPRM) on October 12, 2023, soliciting public comment and suggestions on specific issues related to seed treated with conventional pesticides (treated seed) and paint treated with conventional or antimicrobial pesticides (treated paint). 88 Fed. Reg. 70625. According to the ANPRM, EPA is...

TSCA/FIFRA/TRI EPA Releases Final Guidance For New Pesticide Applications And Registration Review Activities That Require Endangered Species Act Reviews: On September 14, 2023, the U.S. Environmental Protection Agency (EPA) announced the release of final guidance to improve the efficiency of EPA’s Endangered Species Act (ESA) analyses for new pesticide active ingredient applications and active ingredients undergoing registration review. EPA states this guidance fulfills requirements outlined...

TSCA/FIFRA/TRI EPA Posts Resources On Rule To Accelerate Use Of PIPs: The U.S. Environmental Protection Agency (EPA) announced on August 4, 2023, that it is providing resources to help biotechnology developers exercise the full benefits of the exemptions available under the Plant Incorporated Protectants (PIP) exemption rule. These resources are available on EPA’s public website and include the following: The PIPs Exemption Final Rule went into effect on July 31, 2023. More information is...

TSCA/FIFRA/TRI EPA’s Spring 2023 Unified Agenda Includes TSCA, TRI, And PFAS Rulemakings: The U.S. Environmental Protection Agency’s (EPA) spring 2023 Unified Agenda, published on June 13, 2023, includes a number of proposed and final rulemakings under the Toxic Substances Control Act (TSCA) or the Toxics Release Inventory (TRI), as well as rulemakings concerning per- and polyfluoroalkyl substances (PFAS). More information on the rulemakings, including links to our memoranda, is...

WEBINAR — Product Stewardship Practices For Effective Supply Chain Interaction, August 1, 2023, 11:00 a.m. – 12:00 p.m. (EDT): Bergeson & Campbell, P.C. (B&C®) is pleased to present “Product Stewardship Practices for Effective Supply Chain Interaction,” featuring Catherine M. Croke, DBA, Director of Product Stewardship and Regulatory Affairs, B&C; Lee A. Bowers, Vice President, Environmental, Health & Safety, RPM International Inc. (RPM); and...