B&C News: Lautenberg Implementation

October 7, 2021
Chemical Watch Features Comments by Richard E. Engler, Ph.D., Regarding Delays in the TSCA New Chemicals Review Process
On October 7, 2021, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch in the article “TSCA new chemicals review process has ground to a halt, say industry groups.” The TSCA new chemicals review process has "slowed dramatically" over the past year, according to trade groups and industry attorneys, a development they say poses a threat to innovation and the introduction of sustainable chemicals. […] "The current delays are reminiscent of the ‘backlog’ ... read more >
September 22, 2021
PFAS Reporting Rules Webinar Recording and Q&A Document Available Now
Bergeson & Campbell, P.C. (B&C®) is pleased to offer the recording, slides, and written Question and Answer (Q&A) document from our “PFAS Reporting Rules -- What Every Company Needs to Know” webinar, focusing on the U.S. Environmental Protection Agency’s (EPA) proposed reporting rules for per- and polyfluoroalkyl substances (PFAS), presented by B&C Managing Partner Lynn L. Bergeson and Director of Chemistry Richard E. Engler, Ph.D.   Do you wonder if the PFAS reporting rules extend to domestically-produced articles? Or if businesses that incorporate ... read more >
September 14, 2021
Chemical Watch Features Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., Regarding Compliance Challenges of EPA’s PIP Rule
On September 14, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, were quoted by Chemical Watch in the article “US EPA ‘turns up the heat’ on industry to demonstrate PIP rule challenges.” The EPA, however, has made clear that it will not give [companies] further time lightly.  Many commenters "did not provide sufficiently specific information about their operations to support their assertions" that more time was needed to comply, it said ... read more >
September 14, 2021
Lynn L. Bergeson Quoted in Chemical Watch Article “EPA’s timeline to rework TSCA PBT rules ‘impossible to justify’, NGOs say”
On September 14, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding criticism of the U.S. Environmental Protection Agency’s (EPA) decision to grant industry additional time to comply with a Toxic Substances Control Act (TSCA) prohibition on phenol, isopropylated phosphate (3:1) – or PIP (3:1) – in articles.  Some in industry, however, argue the approach represents the agency’s best effort in a tricky situation.  Lynn Bergeson, managing director at Bergeson & ... read more >
August 12, 2021
Richard E. Engler, Ph.D., Quoted in Bloomberg Law Article “Plunge in New Chemical Requests Hurts Innovation, Lawyers Say”
On August 12, 2021, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency’s (EPA) review process for new chemicals. Richard E. Engler, who directs chemistry at Bergeson and Campbell PC, said the EPA still decided to regulate a new chemical after concluding it would pose “no unreasonable risk"—the safest conclusion the agency can reach. Engler said his client provided 100 pages worth of data showing the chemical was safe and needed ... read more >
August 12, 2021
PFAS Reporting Rules -- What Every Company Needs to Know
WEBINAR Thursday, September 9, 2021 11:00 a.m. – 12:00 p.m. (EDT) Register Now PODCAST Available Now Listen Here Transcript Available Here   When it comes to per- and polyfluoroalkyl substances (PFAS), the U.S. Environmental Protection Agency (EPA) is not messing around. The agency announced on June 10, 2021, three actions intended to protect communities from PFAS: proposing a rule designed to obtain comprehensive data on more than 1,000 PFAS manufactured in the United States;   withdrawing guidance that EPA believes weakened its July 2020 significant new use rule (SNUR) ... read more >
August 11, 2021
Lynn L. Bergeson Quoted in Chemical Watch Article “Industry presses US EPA to scale back PFAS reporting rule”
On August 11, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding the compliance challenges of the U.S. Environmental Protection Agency’s (EPA) proposed per- and polyfluoroalkyl substances (PFAS) reporting rule. The language of the NDAA limits the EPA’s ability to make certain changes. For example, it says a final rule must be issued by 1 January 2023, and reporting must cover "each person who has manufactured a chemical substance that is a perfluoroalkyl or polyfluoroalkyl substance ... read more >
July 28, 2021
Register for In-Person TSCA Training Led by Richard E. Engler, Ph.D., at ChemEdge
8:00 a.m. – 2:00 p.m. CDT Wednesday, August 11, 2021, San Antonio, TX There is no better way to prepare yourself and your company to meet TSCA compliance requirements than by enrolling in a day-long workshop lead by Richard E. Engler, Ph.D., Director of Chemistry at Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta) and a 17-year veteran of the U.S. Environmental Protection Agency (EPA). Any company that imports, stores, repackages, processes, uses, or disposes of industrial chemicals is subject to the Toxic Substances Control Act (TSCA). The National Association of ... read more >
July 13, 2021
Recording of “TSCA Reform: Five Years Later” Conference and Other Resources Available Now
The “TSCA Reform - Five Years Later” conference held June 30, 2021, featured in-depth discussion, spirited debate, and news-making statements over the course of six virtual panels. A full recording of the event with additional suggested readings and other resources are available on the Environmental Law Institute (ELI) website for members of ELI.   A detailed summary of the event with commentary is available in Bergeson & Campbell, P.C.’s (B&C®), July 1, 2021, memorandum, “ELI Concludes Another Successful Annual TSCA Conference.” B&C prepared ... read more >
July 12, 2021
Lynn L. Bergeson Quoted in Chemical Watch Article “Fujifilm discontinues US sales of PIP 3:1-containing film”
On July 8, 2021, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding a U.S. Environmental Protection Agency (EPA) plans to begin enforcing PIP 3:1 prohibitions in September. Many businesses and their supply chains were "caught flat-footed" by the restrictions, said Lynn Bergeson, a partner with Bergeson & Campbell who advises companies and trade associations on TSCA compliance and the regulation of chemicals. At the same time, "the passage of a modest amount of time has not moved the needle ... read more >
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