B&C News: Lautenberg Implementation

November 23, 2021
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted by Chemical Watch in “TSCA approach for addressing abandoned PFASs may invite criticism”
On November 23, 2021, Chemical Watch featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, regarding a U.S. Environmental Protection Agency (EPA) plan to use Toxic Substance Control Act (TSCA) significant new use rules (SNUR) to address inactive per- and polyfluoroalkyl substances (PFAS). "The Snur authority is a de facto bar to manufacture/import," Lynn Bergeson and Rich Engler of law firm Bergeson & Campbell said. Requiring companies to submit a significant ... read more >
November 12, 2021
James V. Aidala Quoted in Inside TSCA Article “Former Official Says PFAS Patchwork Shows Failures Of TSCA Preemption”
On November 11, 2021, James V. Aidala, Senior Government Affairs Consultant, Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA’s Inside TSCA regarding state regulations of per- and polyfluoroalkyl substances (PFAS). A former EPA toxics chief says Michigan’s new executive order limiting purchases of products made with per- and polyfluoroalkyl substances (PFAS) not only expands a nationwide patchwork of state-level PFAS policies, but shows that the reformed TSCA’s preemption provision “works on paper, but rarely works in ... read more >
November 9, 2021
Chemical Watch Article “Stakeholders see room for improvement in US EPA’s PFAS categorization” Features Comments by Richard E. Engler, Ph.D.
On November 9, 2021, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Chemical Watch regarding the U.S. Environmental Protection Agency’s (EPA) classification of per- and polyfluoroalkyl substances (PFASs) for company-funded testing under the Toxic Substances Control Act (TSCA). According to Richard Engler, director of chemistry for law firm Bergeson & Campbell, the agency has "come down somewhere in the middle" between examining the huge variety of PFASs as one class and as single compounds, ... read more >
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 >
July 8, 2021
Lynn L. Bergeson Quoted in Bloomberg Law Article "Chemical Reviews Will Ensure Worker Safety, EPA Toxics Head Says"
On July 7, 2021, Bloomberg Law featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a U.S. Environmental Protection Agency (EPA) announcement of policies to review the first round of chemical analyses that were performed under the 2016 amendments to the Toxic Substances Control Act (TSCA). The Biden administration is concerned the Trump administration’s policies to examine chemicals’ risks led to conclusions that ignored too many ways the chemicals might harm people or the environment. Others are concerned ... read more >
July 1, 2021
Comments Made by Lynn L. Bergeson, Michal Freedhoff, Ph.D., and More during TSCA Reform Conference Featured in Bloomberg Law Article "EPA to Revisit Whether Eight Chemicals Too Risky for People"
On June 30, 2021, Bloomberg Law featured quotes from the TSCA Reform – Five Years Later conference regarding a U.S. Environmental Protection Agency (EPA) plan to revisit whether eight chemicals the agency already examined pose greater risks to workers and communities than the Trump administration found. The eight chemicals are seven solvents—methylene chloride, trichloroethylene (TCE), carbon tetrachloride, n-methylpyrrolidone (NMP), 1-bromopropane (1-BP), perchloroethylene (PERC), and 1-4 dioxane—along with the cyclic aliphatic bromide cluster (HBCD), a group of three ... read more >
June 22, 2021
Register Now for “TSCA Reform—Five Years Later” on June 30, 2021
Wednesday, June 30, 2021 9:00 a.m. - 4:30 p.m. (EDT) Register Now 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 “TSCA Reform - Five Years Later.” This complimentary virtual conference marks the fifth Toxic Substances Control Act (TSCA) Annual Conference, reflecting on the accomplishments and challenges since the implementation of the 2016 Lautenberg Amendments and where TSCA stands today. Speakers will dive into a host of topics, including ... read more >
June 18, 2021
Comments by Christopher Blunck Featured in Chemical Watch Article “Breadth of US EPA’s proposed PFAS reporting rule unprecedented, experts say”
On June 17, 2021, Chemical Watch published insights from Christopher R. Blunck, Of Counsel, Bergeson & Campbell, P.C. (B&C®), regarding a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule that includes downstream users and small businesses with a lack of exemptions for the compounds’ occurrence as byproducts or impurities. That is "an extremely broad reporting requirement", said Christopher Blunck, of counsel with Bergeson & Campbell. The proposed rule’s absence of limits or conventional exemptions is "not precedented", he ... read more >
June 17, 2021
Lynn L. Bergeson Quoted in Bloomberg Law Article "EPA’s Flame Retardant Rule Offers Chemical Lesson for Businesses"
On April 9, 2021, Bloomberg Law featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a U.S. Environmental Protection Agency (EPA) rule restricting industrial uses of a popular flame retardant is causing headaches for equipment manufacturers and demonstrating how the nation’s chemicals law can upend global supply chains. But the Environmental Protection Agency was besieged by industry pleas for help soon after the new administration came into office in January, so it took an unusual step. ... read more >
May 27, 2021
Registration Opens for “TSCA Reform – Five Years Later,” an Essential Annual TSCA Event
A Timely and Essential Complimentary Conference Wednesday, June 30, 2021 9:00 a.m. - 4:30 p.m. (EDT) Register Now 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 “TSCA Reform - Five Years Later.” This complimentary virtual conference marks the fifth Toxic Substances Control Act (TSCA) Annual Conference, reflecting on the accomplishments and challenges since the implementation of the 2016 Lautenberg Amendments and where TSCA stands today. ... read more >
May 20, 2021
Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “What would substance-wide TSCA risk determinations and other new approaches mean for stakeholders?”
On May 20, 2021, Chemical Watch featured comments by Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®) regarding recent policy shifts signaled by the US EPA on how it conducts TSCA risk evaluations. Incorporating environmental justice considerations "may present a significant analytical challenge if EPA seeks to move beyond a fenceline cumulative exposure approach", for example, if a worker is exposed at work and then through living near that facility, said Richard Engler, director of chemistry at Bergeson & Campbell.  ... read more >
May 10, 2021
Outstanding TSCA Events This June: Conferences, In-Depth Training, and "TSCA Reform: Five Years Later" Symposium
Lawyers, regulatory experts, and product stewardship professionals engaged in Toxic Substances Control Act (TSCA) compliance have an unusually rich array of conferences and trainings to attend next month.  Professionals of all levels and tenures can find programs to meet their requirements, from one-day key developments updates, to multi-day fundamentals training, to “TSCA Reform: Five Years Later,” the fifth anniversary of this celebrated symposium, presented by the Environmental Law Institute (ELI), the George Washington University Milken Institute School of Public Health, ... read more >
April 9, 2021
Lynn L. Bergeson Quoted in Chemical Watch Article "EPA prepares to issue TSCA PFAS reporting rule proposal"
On April 9, 2021, Chemical Watch featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule under the Toxic Substances Control Act (TSCA), requiring manufacturers to submit detailed information on these compounds to guide potential regulatory action. The US EPA is nearing completion of a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule under TSCA, requiring manufacturers to submit detailed information on these compounds to guide potential ... read more >
April 6, 2021
Save the Date: TSCA At Five Virtual Conference, June 30, 2021
  SAVE THE DATE NEW TSCA AT FIVE Virtual Conference June 30, 2021   This June marks the fifth anniversary of the enactment of the game-changing Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) that amended the Toxic Substances Control Act (TSCA). With a new Administration and the relentless pace of regulatory developments related to Lautenberg implementation, there are many issues to consider and problems to solve. The Environmental Law Institute (ELI), the George Washington University Milken Institute School of Public Health, and Bergeson & ... read more >
March 24, 2021
Product Stewardship and the Pandemic:  Surviving and Thriving in Disruptive Times
March 31, 2021 1:30 p.m. - 3:00 p.m. EDT Register here The COVID-19 global pandemic has had far-reaching impacts on business operations. While we are all eager to put the pandemic behind us, other catastrophic events will inevitably occur. To strengthen organizational resilience going forward, we must examine lessons learned and position product stewardship as a key player in business continuity and crisis management. This complimentary future-focused webinar, hosted by the Product Stewardship Society (PSS), will identify the broad range of complex, unresolved, and evolving issues product ... read more >
March 22, 2021
Spring Arrives with a Slate of Exciting Virtual Events and Trainings
Bergeson & Campbell, P.C. (B&C®) is pleased to share information regarding a full slate of upcoming opportunities for chemical industry stakeholders to stay abreast of key regulatory developments both in the United States and internationally. We hope you will join B&C professionals, industry colleagues, and regulatory agency speakers for one or more of these events.   Key Regulatory Updates:  Europe, Asia and the Americas 2021   March 23-25, 2021 Register here   Chemical Watch presents Key Regulatory Updates: Europe, Asia and the Americas 2021, taking a ... read more >
February 9, 2021
Lynn L. Bergeson and Alexandra Dapolito Dunn to Present "Chemicals Regulation: Latest Developments" at Environmental Law 2021
The American Law Institute Continuing Legal Education (ALI CLE) and the Environmental Law Institute’s (ELI) Environmental Law 2021 webcast educates lawyers on key current environmental law issues, including the latest developments in air, water, endangered species, climate change, chemicals, and renewable energy. A national faculty of seasoned private practitioners, governmental officials, law professors, and public interest advocates will cover what to expect from the change of administrations in Washington D.C., with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. ... read more >
January 28, 2021
Lynn L. Bergeson and Richard E. Engler, Ph.D. Quoted in Chemical Watch Article "TSCA implementation may be ‘significantly different’ under Biden"
On January 28, 2021, Chemical Watch featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C regarding changes to the Toxic Substance Control Act (TSCA) under Biden. "TSCA implementation and interpretation could be significantly different" under the new administration, Lynn Bergeson, managing partner at Bergeson & Campbell, told Chemical Watch. [...] Ms. Bergeson agreed that there is enough ambiguity in the rule to allow for different policy interpretations. "Any ... read more >
January 26, 2021
Comments by Lynn L. Bergeson Featured in Chemical Watch “Global Outlook 2021: Risk assessment and management under TSCA – what should we expect?”
Chemical Watch’s “Global Outlook 2021: Risk assessment and management under TSCA – what should we expect?” includes a conversation between Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Terry Hyland, North America Managing Editor, Chemical Watch, regarding what to expect from the Biden Administration and the U.S. Environmental Protection Agency (EPA) in 2021. Excerpts from the article are below. New challenges also lie ahead for the EPA, still working to update its TSCA fees rule and dealing with legal cases that could bring an ... read more >
January 20, 2021
Comments by Lynn L. Bergeson Discussing Biden Chemical Policy Featured in Bloomberg Environment & Energy Report
On January 20, 2021, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) were featured in the Bloomberg Environment & Energy Report article "Biden Day 1 Presages ‘Far More Aggressive’ Chemicals Stance." Lynn Bergeson, managing partner of Bergeson and Campbell PC, which specializes in chemical policies, saw the selected TSCA rules and policies as focusing on the entire process EPA has used to examine and regulate chemicals through an environmental justice “lens.” That lens will find many problems, she said, ... read more >
January 12, 2021
Richard E. Engler, Ph.D. Quoted in Bloomberg Environment & Energy Report Article "OSHA, EPA to Share Trade Secrets in Joint New Chemicals Work"
On January 12, 2021, Bloomberg Environment & Energy Report featured comments by Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®) regarding an agreement between the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) to share trade secrets about chemicals that manufacturers seek to produce or import. Richard E. Engler, director of chemistry with Bergeson and Campbell PC, said unresolved questions—including who would regulate when—remain. There are situations when either ... read more >
January 7, 2021
WEBINAR -- What to Expect When You're Electing (a New President)
What to Expect When You’re Electing (a New President)   WEBINAR January 28, 2021 1:00 p.m. - 2:00 p.m. EST As a new Administration arrives in Washington, D.C., few things are certain except that 2021 is sure to be an eventful year, especially as the Democrats gain a majority in the House and what appears to be narrow control of the Senate.  While underlying partisan jockeying and prospects for bipartisan cooperation will affect greatly what may happen in the more limited context of chemical regulation, the Biden Administration has already laid out priorities on the ... read more >
December 23, 2020
Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., Featured in Bloomberg Environment Article "Fuel-Chemicals Advisory Seen as ‘Unwanted’ EPA Parting Gift”
On December 23, 2020, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, were featured by Bloomberg Environment regarding a recent U.S. Environmental Protection Agency (EPA) compliance advisory describing how the Toxic Substances Control Act (TSCA) applies to certain petroleum-based chemicals, along with renewable substitutes made from crops, fats, and waste oil. [T]he EPA’s advisory is also “an unexpected and, to many, unwanted parting gift from the Trump ... read more >
December 17, 2020
Lynn L. Bergeson Quoted in Bloomberg Environment Article “Virus Prompts EPA to Let Chemical Makers Split Risk Analysis Fees”
On December 17, 2020, Bloomberg Environment featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a recent U.S. Environmental Protection Agency (EPA) decision to allow chemical manufacturers to split certain risk evaluation fee payments to the agency. [T]he due date for the second payment offers some clarity for clients, said Lynn L. Bergeson, managing partner of Bergeson and Campbell, PC, which specializes in chemical regulations and policies. “Several of our clients have received invoices, and no surprise there,” she ... read more >
September 3, 2020
Register Now for the All Virtual PSX 2020, September 15-17, 2020
Bergeson & Campbell, P.C. (B&C®) is a proud sponsor of the Product Stewardship Society’s (PSS®) PSX 2020 virtual conference.  With a focus on promoting responsible design, development, and management of products throughout their life cycles, the PSX 2020 virtual conference offers a wide variety of education options indispensable to anyone in the chemical industry.  Registration is open now, with a variety of attendance options.  One does not have to be a member of PSS to register, though premium members do receive a 15% discount for the full event. Lynn ... read more >
July 8, 2020
Available On-Demand: “TSCA Reform—Four Years Later” Virtual Seminar
On June 24, 2020, Bergeson & Campbell, P.C. (B&C®), The Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health presented “TSCA Reform -- Four Years Later.”  A full recording of the seminar, including a keynote address by Alexandra Dapolito Dunn, Assistant Administrator, Office of Chemical Safety and Pollution Prevention, U.S. Environmental Protection Agency (EPA), and comments by the Hon. John Shimkus U.S. Representative, 15th District of Illinois, is available to watch now.   This complimentary ... read more >
May 19, 2020
Register for “TSCA Reform—Four Years Later” Virtual Seminar
  “TSCA Reform -- Four Years Later” Provides a Vital Update on Where Lautenberg Implementation Stands Today A virtual day-long symposium presented by the Environmental Law Institute (ELI), Bergeson & Campbell, P.C. (B&C®), and the George Washington University Milken Institute School of Public Health   Free and Open to the Public Wednesday, June 24, 2020 9:30 a.m. - 4:30 p.m. (EDT)   Register Online   B&C, ELI, and the George Washington University Milken Institute School of Public Health are pleased to present "TSCA Reform -- Four ... read more >
May 15, 2020
Lynn L. Bergeson Named among Top 50 Women Super Lawyers in Washington, D.C.; Earns Band 1 Ranking from Chambers and Partners
Bergeson & Campbell, P.C. (B&C®) is pleased to announce that Managing Partner Lynn L. Bergeson has again been recognized by Thomson Reuters’ Super Lawyers as one of the “Top 50 Women” practicing law in Washington, D.C. in 2020. She was also named a Super Lawyer in Environmental Law, a distinction she has earned consistently since 2008.   B&C is also pleased to announce that Ms. Bergeson has earned the highest ranking attainable in Chambers and Partners USA Guide 2020 for Environmental Law -- Band 1. In its review, Chambers states:  ... read more >
May 6, 2020
“TSCA Reform—Four Years Later” Leads an Exciting Slate of Upcoming TSCA Events
“TSCA Reform -- Four Years Later” Leads an Exciting Slate of Upcoming TSCA Seminars, Workshops, and Trainings Bergeson & Campbell, P.C. (B&C®) is pleased to share information regarding a full slate of upcoming opportunities for chemical industry stakeholders to stay abreast of key developments, adjusted due dates, and future plans regarding the implementation of the amended Toxic Substances Control Act (TSCA).    These events are virtual, vital, affordable, and presented in a variety of lengths and formats to fit the schedules of our valued clients as they ... read more >
May 6, 2020
Richard E. Engler, Ph.D., Presents “TSCA New Chemicals” during GlobalChem Webinar Series, May 13, 2020, 12:00 p.m. (EDT)
The 2020 GlobalChem webinar series addresses major developments in chemicals management and provides participants a chance to engage with policymakers and other key experts throughout the chemical industry value chain.  On May 13, 2020, at 12:00 p.m. (EDT), Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), will present during the "TSCA New Chemicals" webinar.  Other presenters include Lynn Dekleva, Ph.D., Associate Deputy Assistant Administrator for New Chemicals, EPA Office of Chemical Safety and Pollution Prevention (OCSPP), ... read more >
April 1, 2020
Acta Group Launches CDR Cross-Check™ To Assist Companies in Identifying Chemical Data Reporting Requirements
The Acta Group (Acta®) announced today 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 EPA (currently, 2016 lists) to identify whether all or some of a company’s inventory of chemical substances are subject to CDR under the Toxic Substances Control Act (TSCA) and, if so, at what reporting threshold. CDR ... read more >
March 25, 2020
Lynn L. Bergeson Quoted in Bloomberg Environment Article “Auto, Other Importers to Get Chemical Fees Break, EPA Says”
On March 25, 2020, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) was quoted by Bloomberg Environment in response to the U.S. Environmental Protection Agency’s (EPA) decision to not go after certain companies that failed to identify themselves to help pay a portion of the chemical risk evaluation fee imposed by a Toxic Substances Control Act fee rule issued in October 2018. The exempted companies include those that import products such as cars, computers, and furniture that contain one or more of the 20 chemicals; manufacturers that produce the ... read more >
March 12, 2020
All Things Chemical™ Episode "TSCA Update — A Conversation with Richard E. Engler, Ph.D."
This week, I sat down with my colleague, Dr. Richard Engler, Director of Chemistry here at B&C and The Acta Group (Acta®). We brought everyone up to date on the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) fee rule and how it applies to entities obligated to pay a portion of the $1,350,000 per chemical fee for preparing an EPA-initiated risk evaluation, the legal and regulatory significance of the supplemental rulemaking on long-chain perfluoroalkyl carboxylate (LCPFAC) chemicals and the precedent it sets for ... read more >
March 6, 2020
Lynn L. Bergeson and EPA Assistant Administrator Alexandra Dapolito Dunn Discuss What to Expect from New TSCA in 2020 as Chemical Risk Evaluations Ramp Up
On March 2, 2020, at ChemCon The Americas 2020 in Philadelphia, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Alexandra Dapolito Dunn, Assistant Administrator, EPA Office of Chemical Safety and Pollution Prevention, sat down with Tjeerd Bokhout to discuss the implementation of Lautenberg and what can be expected through 2020.  Ms. Dunn started off the discussion, noting that EPA is “getting our sea legs under us; we spent the first two or three years after enactment, really through 2019, setting up the bones of the program, the regulations, ... read more >
February 6, 2020
“All Things Chemical™ Podcast Episode "Are You Potentially Responsible for TSCA Fees? EPA Issues Preliminary Lists of Companies Responsible"
This week, I sat down with my colleague, Dr. Richard Engler, Bergeson & Campbell’s Director of Chemistry, to discuss what the fuss is over EPA’s January 27, 2020, issuance of a “preliminary list” of companies responsible for the $1,350,000 per-chemical fee EPA charges to conduct a risk evaluation of a high-priority chemical under TSCA Section 6.  The scope of the entities “on the hook” is far broader than expected, and companies with little understanding of TSCA may be presumptively liable for these fees and TSCA enforcement scrutiny for failure ... read more >
January 23, 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™ training platform offers live in-person training at a company’s site and customized live webinar training, so companies can mix and match training ... read more >
January 15, 2020
Bergeson & Campbell’s Forecast 2020
This week, I sat down with my colleagues Sheryl Lindros Dolan, Chris Bryant, and Dr. Richard Engler to discuss our fabulous 2020 Forecast, B&C’s and The Acta Group’s (Acta®) richly detailed overview of key trends in U.S. and global chemical law and policy. This 67-page document provides a comprehensive “one-stop” overview of global initiatives for the New Year of which stakeholders in the global chemical market must be aware. My colleagues provide a spirited overview of key developments, speculate on the impact of the U.S. general elections later this year, ... read more >
December 18, 2019
Lynn L. Bergeson and Bergeson & Campbell, P.C. Earn Accolades from Who’s Who Legal, U.S. News and World Report, National Law Review, and Lexology
Bergeson & Campbell, P.C. (B&C®) is pleased to announce that Managing Partner Lynn L. Bergeson has again been named one of North America's leading legal practitioners by Who’s Who Legal – Environment. Ms. Bergeson's recognition as a "Leading Individual" by peers and clients notes that she is “highly respected for her top-notch practice where she supports clients in sophisticated regulatory matters in complex biotechnology industries.”  This is the fifteenth year Ms. Bergeson has appeared in Who's Who Legal.   B&C has ... read more >
November 22, 2019
“Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value” Recording Available Now
On November 13, 2019, Bergeson & Campbell, P.C. (B&C®), presented “Value Chain Communications Required under TSCA Consent Orders and SNURs:  How to Formulate Them and Optimize Their Value,” a complimentary webinar for our clients and friends.  Richard E. Engler, Ph.D., Director of Chemistry, B&C, outlined the categories of legally required risk communications to value chain participants required under TSCA Consent Orders and significant new use rules (SNUR).  Lynn L. Bergeson, Managing Partner, B&C, discussed the considerable value of formulating ... read more >
October 16, 2019
WEBINAR -- Value Chain Communications Required under TSCA Consent Orders and SNURs
Value Chain Communications Required under TSCA Consent Orders and SNURs: How to Formulate Them and Optimize Their Value   Wednesday, November 13, 2019 1:00 p.m. - 2:00 p.m. (EST)   Available On Demand   The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) revised the new chemicals review process and existing chemicals risk evaluation scheme.  These changes have triggered the U.S. Environmental Protection Agency’s (EPA) issuance of many more restrictions on chemical substances, necessitating a broad range of risk communications to ... read more >
October 10, 2019
“All Things Chemical™ Podcast Episode "Food Quality, New TSCA, and Much More: A Conversation with Dean Lynn Goldman"
This week, I sat down with Dean Lynn Goldman, the Michael and Lori Milken Dean of the Milken Institute School of Public Health at George Washington University. Dr. Goldman is widely regarded as one of the most influential public health physicians of our time and served as Assistant Administrator for Toxic Substances in the U.S. Environmental Protection Agency from 1993 through 1998 under President Bill Clinton.  During her tenure, Dr. Goldman and her team are credited with implementing the 1996 amendments to our nation’s pesticide law, the Federal Insecticide, Fungicide, and ... read more >
July 18, 2019
WEBINAR - New TSCA at 3:  Key Implementation Issues
  New TSCA at 3:  Key Implementation Issues   Thursday, July 25, 2019 1:00 p.m. - 2:00 p.m. (EDT)    Register Today Overview:   This one-hour webinar will build upon the Bergeson & Campbell, P.C.-sponsored “TSCA:  Three Years Later” one-day conference, co-sponsored by the Environmental Law Institute (ELI) and the George Washington University Milken Institute School of Public Health on June 24, 2019.  The webinar will drill down on key implementation challenges facing industry and the U.S. Environmental Protection Agency (EPA) three ... read more >
June 28, 2019
“TSCA: Three Years Later” Conference Looks to the Past and into the Future
On June 24, 2019, Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health (GWU) presented “TSCA: Three Years Later,” a day-long conference with leading experts exploring the current impacts of the Toxic Substances Control Act (TSCA) on science policies, challenges faced by industry, and the impacts of TSCA on regulatory policies, especially those concerning ensuring compliance and enforcement. A recording of the full conference is available online.   During her ... read more >
May 22, 2019
Registration Now Open For “TSCA: Three Years Later”
  Register Today 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. Goldman, Michael and Lori Milken Dean and Professor, Environmental and Occupational Health, Milken Institute School of Public Health, George ... read more >
April 26, 2019
Lynn L. Bergeson Quoted by Bloomberg Environment in Article “Chemical Rule Sent Back to EPA on Trade Secret Concerns”
On April 26, 2019, Bloomberg Environment quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), regarding a U.S. Court of Appeals for the District of Columbia Circuit ruling that a U.S. Environmental Protection Agency (EPA) rule failed to require chemical manufacturers to sufficiently prove that they have protected their chemical’s secret identity from discovery through reverse engineering. The requirement for companies to substantiate their claims that they have taken steps to prevent their chemicals’ discovery through reverse engineering ... read more >
April 23, 2019
Comments by Lynn L. Bergeson and Kathleen M. Roberts, Included in Bloomberg Environment Article Regarding EPA Chemical Reporting Proposal
On April 23, 2019, Bloomberg Environment featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), in the article “EPA Proposal May Not Streamline Chemical Reporting After All.” Attorneys and other industry consultants told Bloomberg Environment the agency’s proposal would be a mixed bag in terms of saved time. […] Companies would have to spend time learning new codes under an international system the EPA ... read more >
April 3, 2019
B&C Launches TSCA Tutor™ Modular Training Platform
          Bergeson & Campbell, P.C. (B&C®) is pleased to announce an exciting and important new component to our suite of Toxic Substances Control Act (TSCA) offerings. Our TSCA Tutor™ training platform provides live in-person training at a company’s site, live online training, and pre-recorded webinar training modules -- all designed to offer expert, efficient, and essential TSCA training. Companies can mix and match training modules and training approaches to provide the most suitable combination for their work needs. B&C ... read more >
March 22, 2019
Save The Date - June 24, 2019 - New TSCA at 3 Special Event
SAVE THE DATE   New TSCA At Three   Wednesday, June 24, 2019, 9:00 a.m. - 4:30 p.m. (EDT)  Milken Institute School of Public Health George Washington University 950 New Hampshire Ave., N.W., 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 Safety for the 21st Century Act that ... read more >
March 20, 2019
Bloomberg Environment Features Comments by Kathleen M. Roberts Regarding EPA’s High Priority Chemical Determinations
On March 20, 2019, Bloomberg Environment spoke with Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®) and vice president of B&C® Consortia Management LLC (BC-CM), for the article “Industry Advisers Back EPA Strategy on Chemical Vetting.” Looking at several chemicals that serve a similar commercial function can help industry provide the EPA with what it needs to sort the 40 chemicals into the two categories […] For example, the hazards and uses of chemicals in a group will tend to be similar […] It also makes ... read more >
March 1, 2019
Inside EPA Quotes B&C’s Forecast 2019 in the Article “EPA submits TSCA CBI proposal for White House review”
On March 1, 2019, Inside EPA quoted Bergeson & Campbell, P.C.’s (B&C®) Forecast for U.S. Federal and International Chemical Regulatory Policy 2019 regarding ongoing lawsuits that could foreshadow future challenges to the CBI proposal. The law firm Bergeson & Campbell says in its “Forecast 2019” publication that environmentalists' ongoing lawsuit on EPA's “Inventory notification rule … may presage a challenge to the CBI review rule.” The Environmental Defense Fund (EDF) claims that EPA’s 2017 inventory notification rule ... read more >
February 28, 2019
Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., included in Bloomberg Environment Article Regarding Worker Safeguards
On February 28, 2019, Bloomberg Environment featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Director of Chemistry, B&C, in the article “Chemical Law’s Worker Safeguards Ditched by EPA, Advocates Say.” Safety data sheets impose obligations on employers, said Richard E. Engler, director of chemistry for the Bergeson & Campbell PC law firm. The firm manages the TSCA New Chemicals Coalition in which chemical manufacturers share experiences with and concerns about the ... read more >
February 20, 2019
Inside EPA Includes Quotes from James V. Aidala Regarding Alexandra Dunn’s Implementation of TSCA
On February 20, 2019, Inside EPA featured comments by James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®), in the article “New EPA Toxics Chief Seeks To Quell Critics As Agency Implements TSCA.” Jim Aidala, a former EPA toxics chief in the Clinton administration who is now with Bergeson & Campbell, said that Dunn’s confirmation will help the agency navigate its heavy workload in implementing the new law, even as the agency will face stepped-up oversight from House lawmakers and possible criticism from Democratic ... read more >
January 24, 2019
Chemical Watch Features Comments By Lynn L. Bergeson Regarding the Impact of the Shutdown on TSCA Statutory Deadlines
On January 24, 2019, Chemical Watch spoke with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), for the article “Shutdown-related delays could compromise TSCA statutory deadlines.” Lynn Bergeson, managing partner at Bergeson & Campbell, said that the shutdown is stretching the limits of what the EPA is capable of completing in terms of TSCA implementation. "I am concerned simply because we all live in the real world, and we have people who are now, by law, not able to work," she said. "Even for ... read more >
January 18, 2019
Inside EPA Features Excerpts of B&C’s Informative Forecast 2019
On January 18, 2019, Inside EPA extensively quoted Bergeson & Campbell, P.C.’s (B&C®) Forecast 2019 in the article “EPA Shutdown Stymies Looming TSCA Assessment, Rule Deadlines.” Observers are also waiting for EPA to publish its updated TSCA inventory, the list of all existing chemicals, after receiving submissions from industry on which chemicals are deemed active -- manufactured, processed or imported within the past decade -- or inactive. Its publication will start a clock on yet another rulemaking. EPA's framework rule on the TSCA inventory and ... read more >
January 18, 2019
Inside EPA Features Comments by Kathleen M. Roberts Regarding Implementation of TSCA Fee Structure
On January 18, 2019, Inside EPA spoke with Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), for the article “EPA's Fee Rule Takes Effect Without Suit, A First For TSCA Framework.” Kathleen Roberts, a senior regulatory consultant at the law firm Bergeson & Campbell, suggested that the clarity of the statute regarding fees dissuaded critics from challenging EPA's final rule. “I believe that there were no challenges because the legislative language is very clear as to how much EPA could collect in TSCA fees. The ... read more >
January 16, 2019
Chemical Watch Features Comments By Lynn L. Bergeson Regarding the Impact of the Shutdown on TSCA New Chemical Reviews
On January 16, 2019, Chemical Watch spoke with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), for the article “Shutdown spells further delays to TSCA new chemicals reviews.” "Until we have information from the agency, we are more or less assuming that [new chemical review processes] are all suspended, Lynn Bergeson, managing partner at Bergeson & Campbell, told Chemical Watch. And the fear for many is that the shutdown will exacerbate an already overtaxed new chemicals review process, compromising the ability for ... read more >
January 7, 2019
Bloomberg Environment Features Comments By Lynn L. Bergeson and Richard E. Engler, Ph.D., in the Article “Wheeler Pledges More ‘Sunshine’ on Chemical Oversight”
On January 7, 2019, Bloomberg Environment quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, regarding U.S. Environmental Protection Agency (EPA) Acting Administrator Andrew Wheeler’s pledge to make public more information about chemical safety decisions. Richard Engler, director of chemistry at Bergeson & Campbell PC, described Wheeler’s promises as reflecting “EPA’s commitment to fulfilling its responsibilities with regard to transparency in EPA’s TSCA ... read more >
December 19, 2018
Bloomberg Environment Features Comments By Lynn L. Bergeson Regarding EPA’s 2019 Chemical Rules Outlook
On December 19, 2018, Bloomberg Environment spoke with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), for the article “2019 Outlook: ‘Most Active Year Yet’ Looms on EPA Chemical Rules.” The EPA didn’t reply to a question about how many people are working in its chemicals office but said it was allowed to hire up to 340 in fiscal year 2018, an increase from 311 in the previous year. The agency said it couldn’t comment on how many people it will have in fiscal year 2019 until Congress decides on the EPA budget. But the ... read more >
November 26, 2018
Inside EPA References B&C Memorandum On EPA’s First Draft TSCA Risk Evaluation
On November 26, 2018, Inside EPA included information from Bergeson & Campbell, P.C.’s (B&C®) memorandum “EPA Publishes First Draft TSCA Chemical Risk Evaluation” in the article “EPA's PV29 Assessment Likely to Test Reformed TSCA's Data Standards.” In a Nov. 16 memo on the draft's release, the law firm Bergeson and Campbell suggests that there may be little reason to challenge the agency's finding though it leaves the door open to questioning the data EPA relied on. The draft “appears to cover all of the key elements ... read more >
November 13, 2018
Charles M. Auer Quoted In Inside EPA Article “Congress Gears Up For TSCA Oversight But Bipartisan Prospects Limited”
On November 13, 2018, Charles M. Auer, Senior Regulatory and Policy Advisor, Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA regarding Congress’ plan to oversee the U.S. Environmental Protection Agency’s (EPA) implementation of the revised Toxic Substances Control Act (TSCA). “There may be some bipartisan oversight on nuts and bolts questions. But my guess is that each side will generally focus questions on 'their' issues and concerns,” says Charles Auer, a former EPA toxics official who now serves as the senior regulatory and policy ... read more >
November 12, 2018
Richard E. Engler, Ph.D., Interviewed By Rebecca Hersher of Morning Edition
On November 12, 2018, Richard E. Engler, Ph.D., Director of Chemistry for Bergeson & Campbell, P.C. (B&C®), was featured on National Public Radio’s (NPR) morning news program “Morning Edition” during a segment on the chemical methylene chloride.  Reporter Rebecca Hersher asked Dr. Engler, a 17-year veteran of the US Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT) and leader of EPA's Green Chemistry Program, about EPA’s review of methylene chloride and proposed restrictions to consumer use of the ... read more >
November 6, 2018
Richard E. Engler, Ph.D., Quoted By Bloomberg Environment in “Chemical Rule Deluge May Catch Companies Off Guard”
On November 6, 2018, Bloomberg Environment quoted Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), regarding new chemical rules. Before 2016, the EPA took regulatory action on 10-15 percent of new chemicals, clearing the way for 85-90 percent of new compounds to proceed without restrictions, Richard Engler, Bergeson and Campbell PC’s director of chemistry, said. But since the amendments to the nation’s primary chemicals law passed in June 2016, those proportions have switched, he has said. If this trend continues, more firms ... read more >
November 5, 2018
Richard E. Engler, Ph.D., Quoted By Bloomberg Environment Regarding Recent Chemical Rules
On November 5, 2018, Bloomberg Environment quoted Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), in the article “More Sales, Broader Safeguards May Follow Chemical Rule Deluge.” The rules broaden sales opportunities for both the companies that designed these chemicals and ones that want to make or use them, Richard Engler, who was a chemist at the Environmental Protection Agency for 17 years, told Bloomberg Environment. […] The EPA’s release of the new use rules is good news for the original manufacturers, said ... read more >
October 18, 2018
Richard E. Engler, Ph.D., Quoted By Inside EPA in “Despite Suggestion, EPA Floats First SNURs Using Streamlined Framework”
On October 18, 2018, Inside EPA quoted Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), regarding the B&C memorandum “EPA Proposes SNURs that Break New Ground under Amended TSCA.” Industry attorneys are welcoming the agency's approach, suggesting it sets a precedent for future agency action. “The proposed SNUR is interesting, important, and controversial, as this is the first time under the new law for which EPA is proposing to apply SNUR authority to non-[enforcement] order . . . cases,” the Bergeson & ... read more >
October 16, 2018
Inside EPA Quotes B&C’s “EPA Issues Final TSCA Fees Rule” Memorandum
On October 16, 2018, Inside EPA quoted Bergeson & Campbell P.C.'s (B&C®) memorandum “EPA Issues Final TSCA Fees Rule” in the article “EPA finalizes TSCA fees rule but legal challenges possible.” A Sept. 28 memo from the law firm Bergeson & Campbell notes that “the final rule will apply to all submissions that are received starting October 1, 2018. EPA stated that it will invoice affected companies within 30 days of the effective date.” […] Bergeson & Campbell in its memo “appreciate[s] the regulatory and ... read more >
October 12, 2018
Fall 2018 Regulatory, Testing, and Policy Trends for Chemical Consortia
Now more than ever, chemical industry stakeholders with shared business and advocacy interests are urged to consider collaborating on regulatory, testing, and related advocacy opportunities. Two years post-passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act means the U.S. Environmental Protection Agency (EPA) is well underway with implementation of the amended Toxic Substances Control Act (TSCA).      Industry groups that are already established and working efficiently when EPA initiates an action under TSCA will be most successful in nimbly and ... read more >
October 1, 2018
Product Stewardship Society President-Elect Lynn L. Bergeson Moderates “Drivers of Product Stewardship” of Product Stewardship 2018
On September 29, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and President-Elect of the Product Stewardship Society (PSS) moderated the closing session, “Drivers of Product Stewardship: The Role of Regulations, Private Governance, and Managing,” at the 2018 Product Stewardship Conference in Washington D.C. This conference addressed global safety, environmental, and regulatory challenges by bringing together prominent professionals to present and discuss global emerging issues, case studies, practical experiences, and new developments. ... read more >
September 20, 2018
B&C and Bloomberg BNA Present “TSCA Confidential Business Information and Generic Naming: Analyzing the New Rules” Webinar
On September 18, 2018, Bergeson & Campbell, P.C. (B&C®) and Bloomberg BNA presented “TSCA Confidential Business Information and Generic Naming: Analyzing the New Rules,” the fourth webinar in the 2018 Chemical Policy Summit Series. The presenters noted that protecting confidential business information (CBI), including chemical identity, has never been easy but remains an essential component of a successful commercial chemical strategy, and cautioned that amended Toxic Substances Control Act (TSCA) Section 14 is much more prescriptive about what can and cannot be ... read more >
August 10, 2018
B&C’s TSCAblog™ Quoted By Inside EPA Regarding A Call For Clarity On The Reach Of EPA’s Approach To Oxirane Approval
On August 10, 2018, Inside EPA’s article “Industry Backs EPA Chemical Approval But Seeks Clarity On TSCA Process” included comments from TSCAblog’s August 6, 2018, post “EPA Adds Clarity to Interpretation of “Reasonably Foreseeable Conditions of Use”.”  Industry attorneys are welcoming EPA's recent approval of a new chemical that took a narrow view of the substance's “reasonably foreseen uses” that the agency is required to consider, but are urging officials to clarify whether the approach is intended to apply more ... read more >
August 2, 2018
Kathleen M. Roberts Quoted By Bloomberg Environment Regarding New SNURs for 145 Chemicals
On August 2, 2018, Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®) and Vice President, B&C Consortia Management (BCCM), was quoted by Bloomberg Environment in the article “Manufacturers’ Core Questions Remain on EPA’s New Chemical Controls.” Some potential customers won’t purchase any compound regulated by a new use rule, even if the new chemical is better for the environment and safer than alternatives, Kathleen M. Roberts, vice president of Bergeson & Campbell Consortia Management LLC, told Bloomberg ... read more >
July 25, 2018
Lynn L. Bergeson Interviewed By Scott Tong of Marketplace Regarding TCE Ban
On July 24, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) was featured on the radio show Marketplace from American Public Media during a segment on the degreaser Trichloroethylene (TCE) and its status under the Toxic Substance Control Act (TSCA).  Reporter Scott Tong visited the site of a former ViewMaster toy plant outside of Portland, Oregon where TCE has been linked to cancer in some former employees. Tong reported that the U.S. Environmental Protection Agency (EPA) classified TCE as a human carcinogen in 2011, and proposed banning certain ... read more >
July 25, 2018
Richard E. Engler, Ph.D., Quoted by Bloomberg Environment Regarding Late NoC as EPA Updates TSCA Inventory
On July 25, 2018, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding late notices of containment (NoC) filed as the U.S. Environmental Protection Agency (EPA) brings the Toxic Substances Control Act (TSCA) inventory up to date in the article “EPA OK’d Apparent Violations of Chemicals Law.” Sometimes the agency fails to process a commencement notice correctly, said Richard E. Engler, director of chemistry with the Washington office of Bergeson & Campbell P.C. In such cases, the ... read more >
June 25, 2018
Bloomberg Environment Quotes B&C Webinar “TSCA at 2: An Update on Implementation and Hot Topics” In “New Chemical Reviews, Regulations Said to Impede Commerce”
On June 25, 2018, Bloomberg Environment included quotes from Bergeson & Campbell, P.C. (B&C®)’s “TSCA at 2: An Update on Implementation and Hot Topics” webinar in the article “New Chemical Reviews, Regulations Said to Impede Commerce.” The growing number of rules that are accompanying new chemicals is causing marketplace problems, said Michael Gould, environmental, health, and safety committee chairman with RadTech North America. The EPA has been regulating about 90 percent of the new chemicals it has reviewed since TSCA was amended two years ago, ... read more >
June 25, 2018
“TSCA at 2: An Update on Implementation and Hot Topics” Webinar Quoted By Bloomberg Environment
On June 25, 2018, Bloomberg Environment included quotes from Bergeson & Campbell, P.C. (B&C®)’s “TSCA at 2: An Update on Implementation and Hot Topics” webinar in the article “Chemical Companies Get Flexibility in Data Submissions, May Cut Costs.” The EPA will start asking chemical manufacturers to provide certain types of health, ecological, or other data for new chemicals instead of directing them to conduct specific tests of their chemicals, said Nancy Beck, deputy assistant administrator for chemical safety and pollution prevention at the ... read more >
June 18, 2018
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted by Bloomberg Environment Regarding Upcoming EPA Chemical Review Deadlines
On June 18, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Director of Chemistry, B&C, were quoted in the Bloomberg Environment article “Tidal Wave of Toxics Deadlines Awaits EPA, Industries in 2019.” The EPA needs more staff and money to manage its oversight of both existing and new chemicals, said Lynn Bergeson, managing partner of Bergeson & Campbell, PC in Washington. The agency’s chemicals office “will be torn constantly” over the next two years as to where to deploy its ... read more >
June 14, 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. B&C Managing Partner Lynn L. Bergeson and Director of Chemistry Richard E. Engler, Ph.D., co-authored the Pesticides, Chemical Regulation, and Right-to-Know 2017 Annual Report, and B&C Government Affairs Advisor Susan M. Kirsch ... read more >
June 13, 2018
Bloomberg Environment Article “Chemical Makers’ Hours Filling Out Forms Prompts EPA Paper Chase” Features Quotes from Richard E. Engler, Ph.D.
On June 13, 2018, Bloomberg Environment quoted Richard E. Engler, Ph.D., Director of Chemistry at Bergeson & Campbell, P.C. (B&C®) regarding an increase in time required for chemical makers to fill out paperwork under the new Toxic Substances Control Act (TSCA).  The Environmental Protection Agency acknowledged the extra work companies are doing through an “emergency” Paperwork Reduction Act request it submitted to the White House Office of Management and Budget. The EPA will publish the request June 14 in the Federal Register . In its ... read more >
June 13, 2018
Inside EPA Quotes NCC in “New Chemicals Group Seeks Refund Information In EPA's TSCA Fees Rule”
On June 13, 2018, Inside EPA included comments from the Toxic Substance Control Act (TSCA) New Chemicals Coalition (NCC) regarding the omission of language in the U.S. Environmental Protection Agency’s (EPA) proposed fee rule about how it will refund companies whose new chemical use applications are not reviewed by the statutory deadline. Bergeson & Campbell, P.C. (B&C®) provides legal counsel to the TSCA NCC. Membership is open to individual chemical companies with a vested interest in the EPA new chemical notification process due to commercial impacts related to past, ... read more >
June 7, 2018
Richard E. Engler Presents “New TSCA and Green Chemistry Innovation” at ACS Green Chemistry & Engineering Conference
Richard E. Engler, Ph.D., Director of Chemistry at The Acta Group (Acta®) and Bergeson & Campbell, P.C. (B&C®), will present “New TSCA and Green Chemistry Innovation” in the “Real-World Sustainability Challenges: Incentives and Barriers to the Use of Green Chemistry in Products” session on June 18, 2018, at the 22nd Annual Green Chemistry & Engineering Conference (GC&E) hosted by the American Chemical Society’s (ACS) Green Chemistry Institute® that is being held June 18-20, 2018, in Portland, Oregon.  ACS GC&E provides an ... read more >
June 4, 2018
TSCA at 2: An Update on Implementation and Hot Topics
  Monday, June 25, 2018 11:00 a.m. - 12:00 p.m. (EDT)   Register Today   Since enactment on June 22, 2016, of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, the U.S. Environmental Protection Agency (EPA) has implemented a muscular regulatory program expressing Congress’ intent for a new and improved Toxic Substances Control Act (TSCA).  The new TSCA framework required significant work and fundamental shifts in regulatory requirements and conceptual approach, but EPA has hit all of its marks in timely promulgating the rules and fulfilling ... read more >
May 29, 2018
Richard E. Engler, Ph.D, Quoted In Bloomberg Environment Article “Trade Secrets Safe Under EPA Science Proposal, Attorneys Say”
On May 29, 2018, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding a proposed rule that would require scientific data be sufficiently available to the public so that interested parties could understand how the U.S. Environmental Protection Agency (EPA) reached its conclusions. “[D]ecisions the EPA makes about whether to allow new chemicals into commerce would largely be unaffected, Richard Engler, a senior chemist with Bergeson & Campbell, P.C.'s Washington office, told Bloomberg ... read more >
May 23, 2018
The TSCA New Chemicals Coalition: Why Your Company Should Join
Any company that plans to submit or has pending a new chemical notification under the Toxic Substances Control Act (TSCA) needs to join the TSCA New Chemicals Coalition (TSCA NCC) -- the only coalition focused principally on TSCA Section 5 issues. The TSCA NCC has been relentlessly engaging with the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA), and Congress on identifying and addressing real-world issues arising out of EPA’s implementation of the new TSCA Section 5 provisions.   By joining forces with other TSCA NCC ... read more >
May 3, 2018
Chemical Watch Quotes Lynn L. Bergeson Regarding NRDC Brief Challenging EPA’s TSCA New Chemicals Framework Document
On May 3, 2018, text from the March 2018 Global Business Briefing “New TSCA inspires new litigation” written by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted in the Chemical Watch article “NRDC files opening brief in TSCA new chemicals litigation.” Lynn Bergeson, managing partner at law firm Bergeson & Campbell, wrote in Chemical Watch's Global Business Briefing earlier this year that NRDC's legal challenge may well be dismissed on procedural grounds. "The draft ... read more >
May 2, 2018
Bloomberg Environment Article “EPA Chemical ‘Rule’ Flouts Law, Ignores Risks, Critics Tell Court” Includes Comments By Lynn L. Bergeson
On May 2, 2018, Bloomberg Environment quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), regarding a brief filed by NRDC challenging the U.S. Environmental Protection Agency’s (EPA) New Chemicals Framework document. The NRDC’s brief did a good job buttressing its argument that the EPA’s framework warranted public notice and comment, Lynn L. Bergeson, managing partner of Bergeson & Campbell, P.C., said. “Not every such procedural challenge is a winner, but this one at least should be taken seriously,” said ... read more >
April 16, 2018
NR&E Magazine Reviews New TSCA: A Guide to the Lautenberg Chemical Safety Act and Its Implementation
In the Spring 2018 issue of the American Bar Association (ABA) Natural Resources & Environment (NR&E) Magazine, Joanne L. Dunec reviewed New TSCA: A Guide to the Lautenberg Chemical Safety Act and Its Implementation for the Literary Resources section. Dunec wrote, “[t]he balance of the book, written by 11 authors (including the editors), illuminates and analyzes new TSCA in greater detail. The final chapter provides the legislative history of new TSCA, and appendices include an acronym list, frequently asked questions, and a glossary.” New TSCA: A Guide ... read more >
April 9, 2018
Inside EPA Quotes TSCAblog® In “EPA overhauls OPPT leadership”
On April 9, 2018, Inside EPA quoted Bergeson & Campbell, P.C.’s (B&C®) TSCAblog article “EPA Announces OPPT Management Changes” regarding management changes made to U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT). EPA has announced a significant re-shuffling of leaders within its toxics office, which is being reorganized just as officials are working to establish a new program to meet the ambitious deadlines Congress set for implementing the revised Toxic Substances Control Act (TSCA). […] [Maria] ... read more >
April 6, 2018
Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environment Report Article “Staff Shift in EPA's Chemicals Office Prior to Reorganization (1)”
On April 6, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg BNA Daily Environment Report regarding recently announced senior staff job changes at the U.S. Environmental Protection Agency (EPA). The staff moves are taking place before the office's anticipated reorganization, Lynn Bergeson, managing partner of the Bergeson & Campbell, P.C., told Bloomberg Environment.  The agency has not released details of the reorganization nor a timeline, but it is expected later this year, she said. Typically, reorganizations ... read more >
April 3, 2018
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted By Bloomberg BNA Daily Environment Report Regarding EPA Review Process For New Chemicals
On April 3, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Senior Chemist with B&C, were quoted by the Bloomberg BNA Daily Environment Report in the article “EPA Aims for Predictable Chemical Reviews, Director Says.” Richard Engler—a senior chemist with Bergeson & Campbell, P.C.—and Lynn L. Bergeson, managing partner of that same law firm, described some specific types of problems they would like the agency to address. Since 2016, the agency has encouraged companies to meet with EPA ... read more >
March 19, 2018
James V. Aidala Quoted By Bloomberg BNA Daily Environment Report Regarding EPA’s New Science Advisory Committee on Chemicals
On March 19, 2018, James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “New Science Panel May Bolster EPA's Chemical Policy Defense.” If the decision based on [the advisory committee’s] advice is challenged in court, the imprimatur of the outside advisers can offer evidence that the agency used a scientifically credible approach, Jim Aidala, senior government affairs consultant with Bergeson and Campbell P.C. said. Getting and following a science ... read more >
February 21, 2018
Inside EPA Features Comments From B&C “Chemical Regulation in 2018” Webinar
On February 21, 2018, the Inside EPA article, “Beck Suggests Trump Hiring Cap Undermines EPA's TSCA Implementation,” included comments from James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®) and Nancy B. Beck, Ph.D., D.A.B.T., Deputy Assistant Administrator of the U.S. Environmental Protection Agency’s (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP), made at the “Chemical Regulation in 2018: A Sneak Preview of Things to Come” Webinar.  Nancy Beck, the top Trump appointee in EPA's ... read more >
February 9, 2018
Comments by Lynn L. Bergeson Featured in Bloomberg BNA Daily Environment Report Article “Chemical Makers to Pay EPA $20 Million Yearly for Reviews Under Proposal”
On February 9, 2018, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Report regarding a proposed rule that would help defray the U.S Environmental Protection Agency’s (EPA) costs of chemical product reviews. The article also included comments by Nancy Beck, deputy assistant administrator for chemical safety and pollution prevention at EPA, that were made during the B&C/Bloomberg BNA webinar “Chemical Regulation in 2018: A Sneak Preview of Things to Come,” the first event of the five ... read more >
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