November 1, 2020

Monthly Update for November 2020

ABA SEER And CropLife America Present New Developments In Pesticide Law And Policy: Registration is now open for the American Bar Association (ABA) Section of Environment, Energy, and Resources (SEER) and CropLife America virtual conference entitled New Developments in Pesticide Law and Policy on November 18, 2020. The program provides important updates on U.S. pesticide law and policy issues with Lisa M. Campbell, Partner, Bergeson & Campbell,...
October 1, 2020

Monthly Update for October 2020

Lynn L. Bergeson To Present During The Agricultural Law Section Of IBA 2020’s Virtual Conference: The International Bar Association’s (IBA) 2020 Virtually Together conference, occurring November 2-27, 2020, provides an exciting new way to bring the IBA and the world’s legal community together. Lynn L. Bergeson, Managing Partner at Bergeson & Campbell, P.C. (B&C®), and Vice Chair of the IBA’s Agricultural Law Section, will present during, “Opting out of climate...
September 1, 2020

Monthly Update for September 2020

Register Now For 4-Part “TSCA Fundamentals” Course: Bergeson & Campbell, P.C. (B&C®) is pleased to join Chemical Watch to provide in-depth training on the very latest Toxic Substances Control Act (TSCA) regulatory and policy developments, their impact, and how to anticipate their requirements. Staying on top of TSCA changes is critically important, and training on current regulatory requirements is vital for a company to comply with the law and remain commercially...
August 1, 2020

Monthly Update for August 2020

In Memoriam – Timothy D. Backstrom: We write to share the sad news that our friend and colleague Timothy D. Backstrom died on Friday, July 24, 2020. For those clients and colleagues who were fortunate to have known or worked with Tim, you will appreciate the enormous void his untimely demise has left. Tim’s prodigious intellect, his encyclopedic understanding of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), his contributions to the law and regulation of...
July 1, 2020

Monthly Update for July 2020

We announce with sadness that our colleague, Dr. Joseph E. Plamondon, passed away on July 7, 2020. As many in the Toxic Substances Control Act (TSCA) community know well, Joe was renowned in the industrial chemical community for his work on TSCA matters, his presentations at professional events, his extensive writing on chemical regulatory matters, and his wealth of experience across this regulatory arena. For those clients and friends who knew Joe or had occasion...
June 1, 2020

Monthly Update for June 2020

Join Bergeson & Campbell, P.C., The Environmental Law Institute, And George Washington University Milken Institute School Of Public Health For The “TSCA Reform — Four Years Later” Virtual Seminar: From the current impacts of the Toxic Substances Control Act (TSCA) on science policies to challenges faced by industry, Lautenberg Implementation continues to evolve even four years after becoming law. Bergeson & Campbell, P.C. (B&C®), The Environmental Law Institute (ELI),...
May 1, 2020

Monthly Update for May 2020

Join Bergeson & Campbell, P.C., The Environmental Law Institute, And George Washington University Milken Institute School Of Public Health For “TSCA Reform — Four Years Later” Virtual Seminar: From the current impacts of the Toxic Substances Control Act (TSCA) on science policies to challenges faced by industry, Lautenberg Implementation continues to evolve even four years after becoming law. Bergeson & Campbell, P.C. (B&C®), The Environmental Law Institute (ELI), and...
April 1, 2020

Monthly Update for April 2020

Acta Group Launches CDR Cross-Check™ To Assist Companies In Identifying Chemical Data Reporting Requirements: The Acta Group (Acta®) announced on April 1, 2020, the launch of CDR Cross-Check™, an ingenious yet simple tool developed and offered by Acta to assist companies in preparing for the 2020 Chemical Data Reporting (CDR) required by the U.S. Environmental Protection Agency (EPA). CDR Cross-Check utilizes the most recent CDR listing information publicly available provided by...
March 1, 2020

Monthly Update for March 2020

Navigating The Jurisdictional Tightrope Between Biopesticides, Biostimulants, And Related Emerging Technologies, April 29, 2020, 12:00 pm (EDT), Via Webinar: Register for the American Bar Association (ABA) webinar “Navigating the Jurisdictional Tightrope Between Biopesticides, Biostimulants, and Related Emerging Technologies” with Bergeson & Campbell, P.C. (B&C®) professionals deconstructing the jurisdictional boundaries distinguishing pesticides, biopesticides, plant...
February 1, 2020

Monthly Update for February 2020

B&C Launches TSCA Tutor™ Online, On-Demand Training Courses: Bergeson & Campbell, P.C. (B&C®) is pleased to announce the release of the complete suite of TSCA Tutor™ regulatory training courses online and on-demand at www.TSCAtutor.com. Professionals seeking expert, efficient, essential training can preview and enroll in on-demand classes to complete at their own pace and timing. In addition to the newly released online e-learning courses, B&C’s TSCA Tutor™...
January 1, 2020

Monthly Update for January 2020

Forecast For U.S. Federal And International Chemical Regulatory Policy 2020: Bergeson & Campbell, P.C. (B&C®) and its consulting affiliate The Acta Group (Acta®) are pleased to offer you our Forecast 2020. In this detailed and comprehensive document, the legal, scientific, and regulatory professionals of B&C and Acta distill key trends in U.S. and global chemical law and policy, and provide our best informed judgment as to the shape of key developments we are likely to...
December 1, 2019

Monthly Update for December 2019

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends and we wish you and your family a happy, healthy, peaceful, and safe 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. B&C And Acta To Publish Forecast 2020: Start 2020 with...
November 1, 2019

Monthly Update for November 2019

“Value Chain Communications Required Under TSCA Consent Orders And SNURs: How To Formulate Them And Optimize Their Value” Recording Available Now: If you missed this week’s “Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value” webinar, a complimentary recording is available for our clients and friends. Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®),...
October 1, 2019

Monthly Update for October 2019

WEBINAR — RCRA Improvements Rule: An Update and Discussion, October 16, 2019, 1:00 p.m. – 2:00 p.m. EDT: Bergeson & Campbell, P.C. (B&C®) is pleased to present the complimentary webinar “RCRA Improvements Rule: An Update and Discussion,” covering revisions of the regulations that address closure, waste determinations, contingency plans, and emergency preparedness and prevention, among other new requirements that will affect almost 700,000 facilities. Christopher R....
September 1, 2019

Monthly Update for September 2019

Lynn L. Bergeson Named President Of The Product Stewardship Society: The Product Stewardship Society (PSS) Board of Directors inducted Lynn L. Bergeson as President during its annual board meeting preceding the Product Stewardship conference held in Columbus, Ohio, on September 10 – 12, 2019. Ms. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®) and President of The Acta Group (Acta®), will serve as President...
August 1, 2019

Monthly Update for August 2019

Product Stewardship 2019, September 10-12, 2019, Columbus, OH: Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), has served as president-elect of the Product Stewardship Society (PSS) since 2017 and will begin her term as the PSS President during the Product Stewardship Conference. Scott J. Burya, Ph.D., Regulatory Chemist, B&C, will present on regulatory barriers to innovation and how to address them. WEBINAR — Implementation of RMP: A...
July 1, 2019

Monthly Update for July 2019

WEBINAR — New TSCA At 3: Key Implementation Issues, Thursday, July 25, 2019, 1:00 p.m. – 2:00 p.m. (EDT): Bergeson & Campbell, P.C. (B&C®) is pleased to present the complimentary webinar “New TSCA at 3: Key Implementation Issues.” The webinar will drill down on key implementation challenges facing industry and the U.S. Environmental Protection Agency (EPA) three years into navigating the legal, regulatory, and science policy issues arising under the Frank R....
June 1, 2019

Monthly Update for June 2019

TSCA: Three Years Later, Monday, June 24, 2019, 9:00 a.m. – 4:30 p.m. (EDT), Milken Institute School Of Public Health, Washington, D.C.: Join the Environmental Law Institute (ELI), the George Washington University Milken Institute School of Public Health, and Bergeson & Campbell, P.C. (B&C®) for a one-day conference providing updates and insights regarding year three of the federal government’s implementation of the Frank R. Lautenberg Chemical...
May 1, 2019

Monthly Update for May 2019

Registration Now Open For “TSCA: Three Years Later”: Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health are pleased to present the one day conference “TSCA: Three Years Later” on June 24, 2019. Panelists Alexandra Dunn, Assistant Administrator, Office of Chemical Safety and Pollution Prevention (OCSPP), U.S. Environmental Protection Agency (EPA), and Lynn R....
April 1, 2019

Monthly Update for April 2019

WEBINAR — FIFRA Hot Topics In Pesticide, Biocides, And Other Agricultural Chemicals Regulation And Litigation, April 24, 2019, 1:00 p.m. – 2:00 p.m. (EDT): Bergeson & Campbell, P.C. (B&C®) is pleased to present the complimentary webinar “FIFRA Hot Topics in Pesticide, Biocides, and Other Agricultural Chemicals Regulation and Litigation.” Throughout the first few months of 2019, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) issues have been dynamic,...
March 1, 2019

Monthly Update for March 2019

Lynn L. Bergeson, Managing Partner, and Jane S. Vergnes, Ph.D., DABT®, Director of Toxicology, presented “Overview of the Proposed Rule: Strengthening Transparency in Regulatory Science” during the “Data for Chemical Evaluations: Secret or Otherwise” session at The Society of Toxicology’s 58th Annual Meeting held this week in Baltimore, Maryland. For a copy of the presentation, please contact Lynn Bergeson. WEBINAR NEXT WEEK: On March 20, 2019, from 1:00 pm....
February 1, 2019

Monthly Update for February 2019

LAST CHANCE — register now! “Chemical Regulation After the Mid-Terms: What We Can Expect to See in 2019” webinar, Wednesday, February 20, 2019, 1:00 p.m. – 2:00 p.m. EST will feature Alexandra Dunn, Assistant Administrator, Office of Chemical Safety and Pollution Prevention (OCSSP); Beau Greenwood, Executive Vice President, CropLife America; Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®); and James V. Aidala, Senior Government Affairs...
January 1, 2019

Monthly Update for January 2019

Forecast For U.S. Federal And International Chemical Regulatory Policy 2019: Bergeson & Campbell, P.C. (B&C®) and its consulting affiliate The Acta Group (Acta®) are pleased to offer you our Forecast 2019. In this richly detailed document, the legal, scientific, and regulatory professionals of B&C and Acta distill key trends in U.S. and global chemical law and provide our best informed judgment as to the shape of key developments we are likely to see in 2019. We...
December 1, 2018

Monthly Update for December 2018

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends and we wish you and your family a happy, healthy, peaceful, and safe 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. “All Things Chemical” Podcast Focuses On Chemical Law, Business,...
November 1, 2018

Monthly Update for November 2018

B&C Launches All Things Chemical™ Podcast: Bergeson & Campbell, P.C. (B&C®) is pleased to announce the launch of All Things Chemical™, a podcast engaging listeners in intelligent, insightful conversation about everything related to industrial, pesticidal, and specialty chemicals and the law and business issues surrounding chemicals. B&C’s talented team of lawyers, scientists, and consultants will keep listeners abreast of the changing world of both domestic and...
October 1, 2018

Monthly Update for October 2018

Register now for our Wednesday webinar — “Keeping up with FSMA — Rules, Obligations, and Key Compliance Dates,” October 17, 2018, 1:00 p.m. – 2:00 p.m. (EDT). With the pending implementation dates of several core elements of the U.S. Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA), many manufacturers are challenged in addressing efficiently and smartly supply chain complexities. This webinar will help you prepare for the forthcoming deadlines...
September 1, 2018

Monthly Update for September 2018

WEBINAR — TSCA Confidential Business Information And Generic Naming: Analyzing The New Rules, September 18, 2018, 1:00 p.m. – 2:00 p.m. (EDT): Bergeson & Campbell, P.C. (B&C®) and Bloomberg BNA are pleased to present “TSCA Confidential Business Information and Generic Naming: Analyzing the New Rules,” the fourth webinar in the 2018 Chemical Policy Summit Series. Protecting confidential business information (CBI), including chemical identity, has never been easy...
August 1, 2018

Monthly Update for August 2018

PRE-ORDER NOW “Chemical Regulation In The Middle East” By Michael S. Wenk, M.S.: Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce the August 27, 2018, publication of “Chemical Regulation in the Middle East,” written by Michael S. Wenk, M.S., Senior Regulatory Consultant with B&C and Acta. This handbook offers an essential guide to the patchwork of chemical regulatory programs and the complex system of permits and licenses that manage...
July 1, 2018

Monthly Update for July 2018

Available On-Demand – TSCA At 2: An Update On Implementation And Hot Topics: A recording of “TSCA at 2: An Update on Implementation and Hot Topics,” the third webinar in the 2018 Chemical Policy Summit Series, is now available. This webinar featured news and updates on Toxic Substances Control Act (TSCA) implementation from Nancy B. Beck, Ph.D., D.A.B.T.®, Deputy Assistant Administrator, U.S. Environmental Protection Agency (EPA) Office of Chemical Safety and Pollution...
June 1, 2018

Monthly Update for June 2018

Lynn L. Bergeson, Richard E. Engler, Ph.D., And Susan M. Kirsch Contribute To ABA SEER’s The Year In Review 2017: Bergeson & Campbell, P.C. (B&C®) is pleased to announce the publication of The Year in Review 2017: Environment, Energy, and Resources Law by the American Bar Association (ABA) Section of Environment, Energy, and Resources (SEER). The Year in Review 2017 provides an annual summary of developments in environmental, energy, and resources law....
May 1, 2018

Monthly Update for May 2018

TSCA/FIFRA/TRI Webinar: TSCA at 2: An Update on Implementation and Hot Topics: June 25, 2018 11:00 a.m. – 12:00 p.m. (EDT) Register Today Presenters: Nancy B. Beck, Ph.D., D.A.B.T.® Deputy Assistant Administrator Office of Chemical Safety and Pollution Prevention, U.S. Environmental Protection Agency (EPA) Lynn L. Bergeson Managing Partner Bergeson & Campbell, P.C. (B&C®) Others to be announced soon. Overview: Since enactment on June 22, 2016, of the Frank R. Lautenberg Chemical...
April 1, 2018

Monthly Update for April 2018

TSCA/FIFRA/TRI EPA Issues Draft Guidance On Expanded Access To Confidential Business Information: On March 16, 2018, the U.S. Environmental Protection Agency (EPA) released three draft guidance documents for public comment clarifying the circumstances under which EPA may disclose Toxic Substances Control Act (TSCA) confidential business information (CBI) with an expanded set of people. 83 Fed. Reg. 17748. Amended TSCA Section 14(d) expanded the categories of people to whom EPA may disclose...
March 1, 2018

Monthly Update for March 2018

TSCA/FIFRA/TRI EPA Settles With Syngenta On FIFRA Violation Related To Restricted-Use Pesticide: On February 12, 2018, the U.S. Environmental Protection Agency (EPA) announced it has reached an agreement with Syngenta Seeds, LLC (Syngenta), a pesticide company in Hawaii, to resolve alleged violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) at its farm in Kekaha, Kauai. The settlement includes two penalty components: a $400,000 Supplemental Environmental Project...
February 1, 2018

Monthly Update for February 2018

TSCA/FIFRA/TRI Recording Available From “Chemical Regulation In 2018: A Sneak Preview Of Things To Come” Webinar: A recording is now available of “Chemical Regulation in 2018: A Sneak Preview of Things to Come,” the first webinar in the Bergeson & Campbell, P.C. (B&C®)/ Bloomberg Environment 2018 Chemical Policy Summit Series. This focused discussion featured Nancy B. Beck, Ph.D., D.A.B.T., Deputy Assistant Administrator of the U.S. Environmental Protection Agency’s (EPA)...
January 1, 2018

Monthly Update for January 2018

Bergeson & Campbell, P.C.’s (B&C®) much anticipated and highly acclaimed annual Forecast, “Predictions and Outlook for U.S. Federal and International Chemical Regulatory Policy 2018,” is now available. In the Forecast, the lawyers, scientists, and chemical regulatory specialists at B&C and its affiliated consulting firm, The Acta Group (Acta®), offer comprehensive and highly useful observations on the fast-changing and nuanced area of domestic and global chemical legal,...
December 1, 2017

Monthly Update for December 2017

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends and we wish you and your family a happy, healthy, peaceful, and safe 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 Deadline Approaching For Comments On EPA’s Proposed Reporting...
November 17, 2017

Monthly Update for November 2017

TSCA/FIFRA EPA Extends Comment Period For Draft Guidance For Pesticide Registrants On Notifications, Non-notifications, And Minor Formulation Amendments: On October 5, 2017, the U.S. Environmental Protection Agency (EPA) issued a notice of extension of the comment period for the draft guidance Pesticide Registration Notice (PR Notice) 2017-XX: Notifications, Non-notifications and Minor Formulation Amendment issued on September 6, 2017. 82 Fed. Reg. 46491. Comments now must be...
October 1, 2017

Monthly Update for October 2017

TSCA/FIFRA/TRI EPA Schedules PPDC Meeting: On October 13, 2017, the U.S. Environmental Protection Agency (EPA) announced the scheduling of a Pesticide Program Dialogue Committee (PPDC) meeting for November 1-2, 2017. 82 Fed. Reg. 47733. An agenda is expected to be made available by October 18, 2017.PPDC meetings provide the EPA Administrator with advice and information on pesticide issues from stakeholders, including the public, states, and others. EPA Issues Test Methods And...
September 1, 2017

Monthly Update for September 2017

TSCA/FIFRA/TRI EPA Adopts 2017 NAICS Codes For TRI: On August 16, 2017, the U.S. Environmental Protection Agency (EPA) announced that it is updating the list of North American Industry Classification System (NAICS) codes subject to reporting under the Toxics Release Inventory (TRI) to reflect the Office of Management and Budget’s (OMB) 2017 NAICS code revision. 82 Fed. Reg. 39038. As a result, facilities would be required to use 2017 NAICS codes when reporting to TRI beginning...
August 1, 2017

Monthly Update for August 2017

TSCA/FIFRA Bergeson & Campbell, P.C. Forms “TSCA New Chemicals Coalition” JOIN NOW Section 5 of the Toxic Substances Control Act (TSCA) addresses new chemical notifications and, as such, is chemical innovation’s regulatory gatekeeper. The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) amended Section 5. The U.S. Environmental Protection Agency’s (EPA) interpretation of these amendments has changed significantly the Section 5 review process in ways that none...
July 1, 2017

Monthly Update for July 2017

TSCA/FIFRA EPA Releases Final Test Guideline For Performance Against Bed Bugs: On June 14, 2017, the U.S. Environmental Protection Agency (EPA) announced the availability of a final test guideline, Laboratory Product Performance Testing Methods for Bed Bug Pesticide Products; OCSPP Test Guideline 810.3900, part of a series of test guidelines established by the EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP) for use in testing pesticides and chemical substances. 82...
June 1, 2017

Monthly Update for June 2017

Join the Environmental Law Institute (ELI) and the George Washington University Milken Institute School of Public Health on June 27, 2017, for a day-long conference exploring the federal government’s implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which significantly amended the Toxic Substances Control Act (TSCA), just over one year after it was signed into law. This event is free and open to the public. Speakers will discuss key...
May 1, 2017

Monthly Update for May 2017

Lynn L. Bergeson, Environmental Quality Management, Winter 2016: On June 22, 2016, President Obama signed into law the Frank R. Lautenberg Chemical Safety for the 21st Century Act. The text of the law is available at http://www.congress.gov/bill/114th-congress/house-bill/2576/text. The law substantially amends the Toxic Substances Control Act (TSCA), and in so doing, fundamentally alters the domestic management of industrial chemicals, the lifeblood of many manufacturing processes....
April 1, 2017

Monthly Update for April 2017

TSCA/FIFRA EPA Denies TSCA Section 21 TBBPA Petition: On March 17, 2017, the U.S. Environmental Protection Agency (EPA) denied a Toxic Substances Control Act (TSCA) Section 21 petition submitted by, among others, Earthjustice, seeking a TSCA Section 4 test rule for tetrabromobisphenol A (TBBPA). 82 Fed. Reg. 14171. EPA determined that the petition failed to set forth facts demonstrating that there is insufficient information available to EPA to determine or predict reasonably effects from...
March 1, 2017

Monthly Update for March 2017

TSCA/FIFRA/NTP Lynn L. Bergeson, Charles M. Auer, and Carla Hutton, “Practitioner Insights: A Review and Analysis of TSCA Reform Provisions Pertinent to Manufacturers and Processors of Nanoscale Materials,” Bloomberg BNA Daily Environment Report, January 26, 2017: On June 22, 2016, President Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act, Pub. L. No. 114-182, and in so doing significantly revised the Toxic Substances Control Act (TSCA) for the...
February 1, 2017

Monthly Update for February 2017

TSCA/FIFRA/NTP EPA Proposes Regulation Of TCE Use In Vapor Degreasing Under TSCA Section 6(a): On January 19, 2017, the U.S. Environmental Protection Agency (EPA) issued a proposed rule under Section 6(a) of the Toxic Substances Control Act (TSCA) to regulate the use of trichloroethylene (TCE) in vapor degreasing. 82 Fed. Reg. 7432. The proposed rule would prohibit the manufacture (including import), processing, and distribution in commerce of TCE for use in vapor degreasing, prohibit...
January 1, 2017

Monthly Update for January 2017

Bergeson & Campbell, P.C. wishes everyone a healthy, safe, and Happy New Year. If you have not already done so, please read our 2017 Forecast Memorandum, available at /regulatory-developments/entry/predictions-and-outlook-for-u.s.-federal-and-international-chemical-regulat. Register for our complimentary WEBINAR – Chemical Substance Regulation in Central and South America: A Deeper Dive, Thursday, February 16, 2017, 2:00 p.m. Eastern Standard Time. More information...
December 1, 2016

Monthly Update for December 2016

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends and we wish you and your family a happy, healthy, peaceful, and safe 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/IRIS/NTP/TRI EPA Proposes To Add Nonylphenol Ethoxylates To Section...
November 1, 2016

Monthly Update for November 2016

TSCA/FIFRA/IRIS/NTP/TRI EPA Extends Comment Period On Proposed SNUR: On October 21, 2016, the U.S. Environmental Protection Agency (EPA) announced that it has reopened the comment period on a proposed Significant New Use Rule (SNUR) under the Toxic Substances Control Act (TSCA) as requested by a commenter. 81 Fed. Reg. 72759. The proposed rule would amend the TSCA significant new use regulations to align them with revisions to the Occupational Safety and Health Administration’s (OSHA)...
October 1, 2016

Monthly Update for October 2016

TSCA/FIFRA/IRIS/NTP/TRI EPA Issues Statements Of Findings For September 2016: On September 23, 2016, the U.S. Environmental Protection Agency (EPA) issued a notice announcing its findings after its review of Toxic Substances Control Act (TSCA) Section 5(a) notices when EPA makes a finding that a new chemical substance or significant new use is not likely to present an unreasonable risk of injury to health or the environment. 81 Fed. Reg. 65636. Such statements apply to premanufacture...