B&C News: Lautenberg Implementation
October 24, 2016
Conditions of Use, Section 5 Review Period Flexibility?, and Other Resources
Role of “Conditions of Use” Under Sections 5 and 6 of Amended Toxics Law
The concept of “conditions of use” plays an important role in the Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act. Conditions of use is a centralizing concept under which the U.S. Environmental Protection Agency (EPA) determines how a chemical is made, processed, used, and disposed. The term is defined in Section 3 and also appears one or more times in the following Sections: 5, 6, 9, 14, 18, 21, and ... read more >
September 21, 2016
Lynn L. Bergeson, Michael S. Wenk, M.S., and J. Brian Xu, M.D., Ph.D., DABT®, to Speak at ChemCon The Americas 2016
October 17 - 21, 2016, Toronto, Canada
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are proud to once again be sponsors of and program advisors to ChemCon, a global chemical control conference offering authoritative speakers, in-depth sessions, and global perspective on existing and emerging chemical regulatory schemes.
Highlights from the diverse and substantive program planned for Toronto include:
Workshop on the modernized Toxic Substances Control Act, with speakers including Jeff Morris, Deputy Director, U.S. Environmental Protection Agency (EPA) ... read more >
September 20, 2016
“The New TSCA” Webinar 4: Administration of the Act, Preemption, Fees, and Green Chemistry
Tuesday, October 4, 2016
8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time
Three months have passed since Toxic Substances Control Act (TSCA) reform was enacted and now implementation trends are starting to take shape. Rather than waiting to see what TSCA reform's impact on your business might be, take control of your approach to "new" TSCA with the information and insight shared in "The New TSCA: What You Need To Know" webinar series presented by Chemical Watch and Bergeson & Campbell, P.C. ... read more >
September 12, 2016
Charles M. Auer, Former Director of EPA Office of Pollution Prevention and Toxics (OPPT), Joins Bergeson & Campbell, P.C. and The Acta Group
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are very pleased to announce that Charles M. Auer has joined our teams as Senior Regulatory and Policy Advisor. For more than three decades, Mr. Auer has provided sagacious, informed, and deeply insightful guidance on legal, policy, and scientific matters related to the regulation of chemicals under the Toxic Substances Control Act (TSCA) and related domestic and international chemical control laws. Mr. Auer's experience includes over 32 years at the U.S. Environmental Protection Agency (EPA), most recently as the ... read more >
September 7, 2016
“The New TSCA” Webinar 3: Inventory, CDR, and CBI (Sections 8 & 14)
REMINDER
"'The New TSCA' -- What You Need To Know" Webinar 3: Inventory, CDR, And CBI (Sections 8 & 14)
Monday, September 12, 2016
8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time
Register Today
Three months have passed since Toxic Substances Control Act (TSCA) reform was enacted and now implementation trends are starting to take shape. Rather than waiting to see what TSCA reform's impact on your business might be, take control of your approach to "new" TSCA with the information and insight shared in the ... read more >
August 30, 2016
Register for the “New TSCA” Webinar 3: Inventory, CDR, and CBI (Sections 8 & 14) Sept. 12, 2016
Monday, September 12, 2016
8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time
Register Today
Speakers:
Charles M. Auer, Charles Auer & Associates, LLC, former Director of the Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA)
Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C.
Richard E. Engler, Ph.D., Senior Chemist, Bergeson & Campbell, P.C., former senior staff scientist in OPPT and leader of EPA's Green Chemistry Program
Kelly Franklin, ... read more >
August 25, 2016
B&C Memoranda Featured In Inside EPA Article, “Attorneys Say Proposed TSCA Rule May Violate Trade Secret Provisions”
On August 25, 2016, the Bergeson & Campbell, P.C., (B&C®) memoranda “TSCA Reform: Proposed Changes to SNUR Procedures Would, Perhaps Inadvertently, Result in Disclosure of CBI to Third Parties/Possible Competitors” and “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” were discussed in an Inside EPA article on how Toxic Substances Control Act (TSCA) Reform may violate trade secret provisions.
"We do not read provisions in either old or new TSCA to authorize EPA to disclose CBI ... read more >
August 18, 2016
Chemical Watch Article “Law firm flags up issues in EPA Snur proposal” Quotes B&C Memorandum Conflict Between SNURs And Revised OSHA HCS
On August 18, 2016, Chemical Watch quoted the Bergeson & Campbell, P.C. (B&C®) memorandum, “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” in an article examining the conflict between the U.S. Environmental Protection Agency’s (EPA) Significant New Use Rule (SNUR) proposal and the revised Occupational Safety and Health Administration's (OSHA) Hazard Communications Standard (HCS).
US agency's notice 'downplays' magnitude of changes, says Bergeson & Campbell.
The US ... read more >
August 11, 2016
Bloomberg BNA Daily Environment Report Article, “Fees Must Not Stymie Innovation, Chemical Makers Tell EPA,” Includes Comments From Kathleen M. Roberts
On August 11, 2016, the Bloomberg BNA Daily Environment Report quoted Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C. (B&C®), on the implication of additional fees created by Toxic Substance Control Act (TSCA) reform.
Companies that pay the costs of generating toxicity, exposure and other data should not be “double billed” through additional fees to review the resulting information, said Walls and Kathleen Roberts, vice president of Bergeson & Campbell Consortia ... read more >
August 11, 2016
IHS Chemical Week Quotes Lynn L. Bergeson On EPA Implementing TSCA Reform
On July 11, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), was quoted in the IHS Chemical Week article “Responsible Care: TSCA reform and enhancing product safety.”
“Chemical companies need to start paying attention to what EPA is doing and announcing—and raise concerns so they can be heard.” Lynn Bergeson, a managing partner at environmental law firm Bergeson & Campbell, agrees, adding chemical companies should “carefully monitor [EPA’s] rulemaking process immediately.”
Bergeson said that there ... read more >
July 25, 2016
Inside EPA Quotes B&C Memorandum In Article “EPA Issues First New Chemical Safety Reviews Under Reformed TSCA Law”
On July 25, 2016, Inside EPA quoted Bergeson & Campbell P.C.’s (B&C®) memoranda “EPA Releases First Determinations for New Chemicals under New TSCA,” on the U.S. Environmental Protection Agency’s (EPA) use of structure activity relationship (SAR) in premanufacture notice (PMN) reviews.
In a July 22 memo to clients and colleagues, the law firm Bergeson & Campbell also notes that EPA appears to have used structure activity relationship (SAR) modeling in its analyses, though the firm, unlike Denison, applauded the use of these ... read more >
July 22, 2016
Bloomberg BNA Daily Environment Report Quotes Lynn L. Bergeson In “First Decisions on New Chemicals Made Under Amended TSCA”
On June 22, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in Bloomberg BNA Daily Environment Report discussing the new Toxic Substances Control Act (TSCA) chemical regulatory process.
Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA: “On the whole, the process seems to be efficient, but stakeholders will need to monitor the ... read more >
July 15, 2016
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article On The Need To Submit Thoughtful PMNs to EPA
On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), in the article, “Give EPA Detailed New Chemical Notices, Attorneys Advise.”
Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much more strategic, thoughtful and detailed,” Lynn Bergeson, managing partner of ... read more >
July 14, 2016
Bloomberg BNA Daily Environment Report Quotes Lynn L. Bergeson On New TSCA Chemical Provisions
On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), in the article “Give EPA Detailed New Chemical Notices, Attorneys Advise.”
Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much more strategic, thoughtful and detailed,” Lynn Bergeson, managing partner of ... read more >
July 13, 2016
B&C Webinar Featured In Bloomberg BNA Daily Environment Report Article “Companies Need EPA to Specify Exposure Texts for TSCA Data”
On July 14, 2016, Bloomberg BNA Daily Environment Report included quotes from the B&C® and Chemical Watch webinar “The New TSCA Series Webinar 2: Impacts on New Chemical Programs.”
Chemical manufacturers and processors will need to give exposure and toxicity data to the EPA for it to evaluate the risks of new and existing chemicals as required by the recently amended Toxic Substances Control Act, said Charles Auer, who directed the EPA Office of Pollution Prevention and Toxics under multiple administrations. Auer spoke July 14 during a webinar ... read more >
July 11, 2016
Lynn L. Bergeson Comments On TSCA Implementation Featured In Bloomberg BNA Daily Environment Report Article “More Than 300 New Chemicals Snagged as EPA Implements Law”
On July 12, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “More Than 300 New Chemicals Snagged as EPA Implements Law.”
Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA July 11 the number of new chemicals affected by the EPA's implementation of the newly amended Toxic Substances Control Act isn't large.
For an individual company, however, every day that delays its ability to bring a new chemical or a new use ... read more >
June 30, 2016
“Amended Law Affecting New Chemicals’ Market Entry,” Article Quotes Lynn L. Bergeson On PMN Reviews
On June 30, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “Amended Law Affecting New Chemicals' Market Entry,” discussing the impact of Toxic Substances Control Act (TSCA) Reform on U.S. Environmental Protection Agency (EPA) premanufacture notifications (PMNs) reviews.
Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA June 30 that because of the changes, the Environmental Protection Agency “reset the clock” and ... read more >
June 29, 2016
Chemical Watch Webinar Series -- "'The New TSCA' - What You Need to Know"
Webinar 2: "Impacts on New and Existing Chemicals Programs"
Thursday, July 14, 2016
8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time
Register Today
In this second episode of the complimentary webinar series "The New TSCA -- What You Need To Know," Chemical Watch and an assembled faculty of Toxic Substances Control Act (TSCA) experts will take a deeper dive into the profound changes that the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) makes to TSCA Sections 4, 5, and ... read more >
June 29, 2016
B&C Memorandum Quoted In Inside EPA Article, “Chemical Sector Sees Early Concerns With EPA TSCA New Chemicals Plan”
On June 29, 2016, Inside EPA quoted the Bergeson & Campbell P.C. (B&C®) memorandum, “TSCA Reform: An Analysis of Key Provisions and Fundamental Shifts in the Amended TSCA,” analyzing the new TSCA law.
The law firm Bergeson & Campbell in a June 22 analysis of the new law says that the amended section 26(p) of TSCA "arguably afford EPA broad discretion to establish procedures for disposing of any Section 5 cases that are pending before EPA (including those under voluntary suspensions) at the time of enactment."
The firm says the ... read more >
June 23, 2016
Bergeson & Campbell, P.C. Launches TSCAblog.com to Provide News and Analysis on TSCA Reform Implementation and Related Legal and Policy Developments
Bergeson & Campbell, P.C. (B&C®) announced today the launch
of the Toxic Substances Control Act (TSCA) Blog (TSCAblog™)
to track and report regulatory, scientific, legal, and policy
developments under the "new TSCA." On June 22, 2016,
President Obama signed into law the Frank R. Lautenberg
Chemical Safety for the 21st Century Act (Lautenberg), which
makes important changes to TSCA and is the first revision of
U.S. domestic chemical management law in 40 years.
Stakeholders will need immediately to understand what the
"new TSCA" means for their industrial operations ... read more >
June 22, 2016
James V. Aidala Quoted In Bloomberg BNA Daily Environment Report Article “EPA Must Adjust to New Toxics Law, Former Officials Say”
On June 22, 2016, James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®) was quoted in a Bloomberg BNA Daily Environment Report article on the expected U.S. Environmental Protection Agency (EPA) implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
Jim Aidala, former head of the EPA Office of Pollution Prevention and Toxics, told Bloomberg BNA the first few months of implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act will be “chaotic in the happy ... read more >
June 17, 2016
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “California Agency To Look At TSCA Reform Impacts On Safer Consumer Products Effort”
On June 17, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “California Agency to Look at TSCA Reform Impacts on Safer Consumer Products Effort.”
Lynn Bergeson, managing partner of Bergeson & Campbell PC, said federal preemption would apply only to certain actions, such as restrictions.
It wouldn’t extend to state laws that require reporting or monitoring.
‘‘That said, TSCA preemption would appear to have its most potentially consequential impact on ... read more >
June 16, 2016
Chemical Watch Quotes James V. Aidala On TSCA Reform Implementation
On June 16, 2016, James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell P.C. (B&C®), was quoted in the Chemical Watch article “EPA Implementation Of TSCA To Be ‘Enormous Undertaking.’”
The Lautenberg Act sets out “very aggressive deadlines” that will “not be easy to meet”, agreed Jim Aidala – a former Assistant Administrator for the EPA Office of Prevention, Pesticides, and Toxic Substances (OPPTS) and senior government consultant at Bergeson & Campbell – during ... read more >
June 16, 2016
Bloomberg BNA Daily Environment Report features comments by Lynn L. Bergeson On Conflicts Between TSCA Reform and California DTSC
On June 16, 2016, Lynn L, Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article, “California Agency Examining Impacts of TSCA-Reform Bill.”
Lynn Bergeson, managing partner of Bergeson & Campbell PC, said federal preemption would apply only to certain actions, such as restrictions.
It wouldn't extend to state laws that require reporting or monitoring.
“That said, TSCA preemption would appear to have its most potentially consequential impact on the Safer Consumer ... read more >
June 15, 2016
B&C Memorandum Quoted In Inside EPA Article On TSCA Reform
On June 15, 2016, Bergeson & Campbell P.C.’s (B&C®) memoranda, “TSCA Reform: An Analysis of Key Provisions and Fundamental Shifts in the Amended TSCA,” was quoted in the Inside EPA article, “Questions Linger On EPA Approach To TSCA Bill's New Chemicals Program.”
"While Lautenberg appears to afford EPA the discretion needed to fashion an appropriate transitional policy for disposing of currently pending and suspended Section 5 notices, it does not require EPA to do this," a May 25detailed review of the final TSCA ... read more >
June 13, 2016
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article On Impact Of TSCA Reform On Pending Chemical Rules For Articles
On June 13, 2016, the Bloomberg BNA Daily Environment Report article, “TSCA Changes May Alter Pending Chemical Rules for Articles,” included comments by Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®).
The EPA may need to conduct new analyses to support its proposed rules or the agency may need to re-propose them in light of changes the TSCA-reform bill would make to the criteria the agency should use when regulating manufactured goods, or “articles,” said Lynn Bergeson, managing partner of Bergeson & Campbell ... read more >
June 10, 2016
Bloomberg BNA Daily Environment Report Article “Law Firms Help Clients Prep for New Chemicals Law” Quotes Lynn L. Bergeson
On June 10, 2016, Bloomberg BNA Daily Environment Report included comments from Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), speaking about the impacts of passing the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
[…] “The bill's many deadlines will drive EPA activities at a frantic pace,” said Lynn Bergeson, managing partner of Bergeson & Campbell.
[…] Among the deadlines the EPA faces in the first year of the law's implementation:
• review final legislative ... read more >
June 9, 2016
Boston Commons High Tech Network Article “US Congress Passes Landmark Chemical Safety Reforms” Includes Comments From James V. Aidala
On June 9, 2016, James V. Aidala, Senior Government Affairs Consultant at Bergeson & Campbell P.C. (B&C®), was quoted in a Boston Commons High Tech Network article on the passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act overhauling the Toxic Substances Control Act (TSCA).
Jim Aidala, a former EPA official who is now with consultants Bergeson & Campbell PC, said the legislation helps define which toxic chemicals the EPA can ... read more >
June 8, 2016
Chemical Watch Offers Complimentary Webinar Series on "The New TSCA"
Register Today For "The New TSCA -- Overview and Summary of Major Changes: What to Expect and When to Expect It"
Monday June 13, 2016
8:00 a.m. Pacific Daylight Time / 11:00 a.m. Eastern Daylight Time / 4:00 p.m. British Summer Time
Speakers:
Lynn L. Bergeson, Managing Partner, Bergeson & Campbell P.C.
Richard A. Denison, Ph.D., Lead Senior Scientist, Environmental Defense Fund
Charles M. Auer, Charles Auer & Associates, LLC, former Director of the Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA)
James V. Aidala, Senior ... read more >
June 8, 2016
Bloomberg Article “EPA Wins Clout To Fight Toxic Chemicals, But It May Take A While,” Quotes James V. Aidala
On June 8, 2016, Bloomberg Politics quoted Senior Government Affairs Consultant for Bergeson & Campbell P.C. (B&C®), James V. Aidala, on how the overhaul of the Toxic Substances Control Act (TSCA) will impact the U.S. Environmental Protection Agency’s (EPA) ability to regulate chemicals.
"It’s a very ambitious undertaking -- it’s going to be hard," said James Aidala, the former head of EPA’s chemical safety office and a consultant at Bergeson & Campbell. "It is going to take a long time, even if the administration gives the program a ... read more >
June 8, 2016
Bloomberg BNA Daily Environment Report Quotes James V. Aidala On Implementation Of TSCA Reform
On June 8, 2016, the Bloomberg BNA Daily Environment Report article, “With Chemical Safety Law, Congress Hands EPA Herculean Task,” quoted James V. Aidala, Senior Government Affairs Consultant for Bergeson & Campbell P.C. (B&C®).
“It's a very ambitious undertaking—it's going to be hard,” said James Aidala, the former head of EPA's chemical safety office and a consultant at Bergeson & Campbell. “It is going to take a long time, even if the administration gives the program a slug of money on day ... read more >
June 7, 2016
Lynn L. Bergeson Quoted In Chemical Week Article “TSCA Reform On The Horizon As Bill Passes Senate (Update)”
On June 7, 2016, Chemical Week quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), about the challenges facing the implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
Lynn Bergeson, managing partner of Bergeson & Campbell, P.C., says the new program will face a variety of hurdles because of the challenge of deadlines, resources, and "only a short (if any) honeymoon period. It might take a significant length of time before regulations, policies, and new procedures are up and running to implement fully the new ... read more >
June 7, 2016
Lynn L. Bergeson Quoted In Foreign Direct Investment (fDi) Magazine Article On The Impacts Of TSCA Reform
On June 7, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in fDi Magazine’s article “TSCA reform bill ‘beneficial to foreign investors and manufacturers.’” fDi Magazine is affiliated with fDi Intelligence, a division of the Financial Times Ltd, and is a premier publication for the business of global investments. The article discusses major changes that will result from TSCA Reform, including more funding for the U.S. Environmental Protection Agency (EPA), easier access to company chemical data, and a larger ... read more >
June 7, 2016
Lynn L. Bergeson Quoted In Wall Street Journal Article “Updated Rule Offers Better Oversight of Nanotech Chemicals”
On June 7, 2016, the Wall Street Journal Risk & Compliance Journal reporter Ben DiPietro featured quotes by Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), about the impact of Toxic Substances Control Act (TSCA) Reform on nanotechnology chemicals. The article “Updated Rule Offers Better Oversight of Nanotech Chemicals” explores how many nanotech chemicals were mostly ignored by the language of TSCA, but may now be reviewed by the U.S. Environmental Protection Agency (EPA) in order to determine accurate associated risks.
Some of the ... read more >
June 1, 2016
Lynn L. Bergeson Quoted In Inside EPA Article “TSCA Reform Bill Might Set New Limits On EPA’s Regulation of ‘Articles’”
On June 1, 2016, Lynn L. Bergeson, Bergeson & Campbell P.C. (B&C®) Managing Partner, was quoted in an Inside EPA article regarding possible Toxic Substances Control Act (TSCA) Reform impacts on the U.S. Environmental Protection Agency’s (EPA) ability to regulate chemicals in finished products.
EPA has not yet provided a cohesive regulatory policy on articles, so having a statutory requirement could ease some of those concerns, said Lynn Bergeson, managing partner at Bergeson & ... read more >
May 26, 2016
The New TSCA Webinar 1 - Overview and Summary of Major Changes: What to Expect and When to Expect It
Date: June 13, 2016, 11:00 a.m. (EDT), 8:00 a.m. (PDT)
Price: Complimentary - click here to register
Topics covered:
Key terms needing legal interpretation
Chemical prioritization
Pace of existing chemical reviews
Changes to new chemicals process
Implementation deadlines
Rulemaking
Fees
"Sound science"
Speakers:
Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C.
Charles M. Auer, Charles Auer & Associates, LLC, former Director of the Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA)
Richard A. Denison, ... read more >
May 26, 2016
TIME Magazine Quotes Lynn L. Bergeson In “Will Congress’s Chemical Safety Reform Protect Us? It Depends”
On May 26, 2016, TIME Magazine published an article, “Will Congress’s Chemical Safety Reform Protect Us? It Depends," reporting on the bipartisan passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, quoting Managing Partner of Bergeson & Campbell P.C. (B&C®), Lynn L. Bergeson.
In the past, states have stepped in to regulate chemicals in the absence of leadership by the federal government. Lynn Bergeson, managing partner at the environmental law and government affairs firm Bergeson & Campbell, says the new approach could be seen ... read more >
May 23, 2016
James V. Aidala Quoted In Washington Examiner Article “White House Backs Congress’ Chemical Safety Overhaul”
On May 23, 2016, Senior Government Affairs Consultant for Bergeson and Campbell P.C. (B&C®), James V. Aidala, was quoted in the Washington Examiner article “White House Backs Congress’ Chemical Safety Overhaul."
Jim Aidala, a former EPA official who is now with consultants Bergeson & Campbell PC, said the legislation helps define which toxic chemicals the EPA can regulate.
He expects the House to take up its version of the bill this week. He doesn't expect the Senate to vote on its companion bill until after the Memorial Day ... read more >
April 21, 2016
Lynn L. Bergeson Presents “The New TSCA Regulatory Framework Post-TSCA Reform” At The 2016 Adhesive and Sealant Council Spring Conference
On April 20, 2016, Lynn L. Bergeson presented on the regulatory framework created by reforming the Toxic Substances Control Act (TSCA) at the 2016 Adhesive and Sealant Council (ASC) Spring Conference. Throughout the course of the presentation, “The New TSCA Regulatory Framework Post-TSCA Reform,” Ms. Bergeson discussed the future of chemical management under TSCA regardless of when action is taken to implement TSCA reform. The presentation covered TSCA’s core provisions and authorities; key concerns with TSCA; current TSCA and downstream users; TSCA reform legislation and ... read more >
December 14, 2015
Chemical Watch Includes Extensive Comments By Lynn L. Bergeson On Impacts Of TSCA Reform
The December 14, 2015, Chemical Watch article “TSCA Bill Could Have 'Huge' Impact On Downstream Users,” included quotes from Lynn L. Bergeson on possible results of TSCA Reform.
Changes to the chemical inventory as proposed in the US Senate Toxic Substances Control Act (TSCA) reform would have a “huge” impact on downstream users, according to Lynn Bergeson, owner of Bergeson & Campbell, PC. Bill S697 proposes to reset the TSCA Inventory of Chemical Substances to determine which chemicals are still active and which are inactive.
Ms Bergeson said she ... read more >
December 11, 2015
Chemical Watch Quotes Lynn L. Bergeson On Possible Future Of TSCA Reform
On December 11, 2015, Chemical Watch, quoted Lynn Bergeson in the article “Senate TSCA Bill More Aligned With EPA Principles, Says Denison.”
Lynn Bergeson, managing partner of Bergeson & Campbell, said it is possible that the Senate will approve S-697 before Congress adjourns in mid-December. “Until it emerges from the Senate we can’t have any further action on the bill,” ... read more >
December 1, 2015
Request Recording and Materials from Panel Discussion with EPA Alumni: "TSCA Reform: What’s Happening Now, and What’s Next?"
Request Recording and slides from “TSCA Reform Panel Summit: What’s Happening Now, and What’s Next?”
Program informational flyer
George Washington University (GWU) Milken Institute School of Public Health, GWU Law School, Environmental Law Institute, Arnold & Porter LLP, and Bergeson & Campbell, P.C. Present: TSCA Reform Panel Summit: What's Happening Now, and What's Next?
Thursday, November 19, 2015, 12:00 – 1:30 p.m. (EST)
George Washington University Milken Institute School of Public Health Main Auditorium, 950 New ... read more >
November 24, 2015
Inside EPA Article Quotes Jim Aidala On TSCA Reform Vote
On November 24, 2015, Inside EPA published the article “TSCA Bill Faces Implementation Hurdles Despite Potential For Senate Vote.” Jim V. Aidala was quoted discussing a possible implementation timeline if the TSCA Reform bill was passed.
Former EPA toxics official Jim Aidala, now with the law firm Bergeson & Campbell, at the ELI event identified some of the time frames on rulemakings, new definitions, and administrative fees as potential "early implementation hurdles" associated with reform legislation if it clears a Senate floor ... read more >
November 10, 2015
Lynn L. Bergeson Quoted Extensively In BNA Daily Environment Report Article “Nanomaterials Said to Illustrate Need for TSCA Reform”
The November 10, 2015, BNA Daily Environment Report article "Nanomaterials Said to Illustrate Need for TSCA Reform" included comments from Lynn L. Bergeson and the NanoBusiness Commercialization Association (NanoBCA) on the importance of TSCA reform for nanomaterials.
[…]Lynn Bergeson, managing partner of Bergeson & Campbell P.C., said the EPA could have used the authority the House and Senate [TSCA modernization] bills would give the agency to order the submission of existing data, without rulemaking. The information from such a data call-in could have increased ... read more >
October 20, 2015
Invitation to TSCA Reform Panel Summit at GW University
George Washington University Milken Institute School of Public Health,
George Washington University Law School,
Environmental Law Institute, and
Bergeson & Campbell, P.C. Present:
TSCA Reform Panel Summit: What's Happening Now, and What's Next?
November 19, 2015
12:00 – 1:30 p.m. (EST)
In-person and via Webcast
Betting on passage by Congress of Toxic Substances Control Act (TSCA) reform is anything but a sure thing. While most remain optimistic, with each passing day the window of opportunity is narrowed. One possibility is that some version of the bipartisan Senate ... read more >
June 24, 2015
BNA Daily Environment Report Includes Comments from Lynn L. Bergeson Regarding TSCA Modernization Act
The June 24, 2015 Bloomberg BNA Daily Environment Report included quotes from Lynn L. Bergeson in the article “Bill to Update Toxic Substances Control Act Sails Through House by 398-1 Vote.”
Lynn Bergeson, managing partner of Bergeson & Campbell P.C., told Bloomberg BNA in a June 23 e-mail that the changes in the bill prior to the House vote seemed to reflect the need for consensus more than anything.
‘‘EPA will be challenged to complete risk evaluations in two years. Complex chemicals with multiple uses will be exceedingly hard to complete in 24 months and EPA ... read more >
June 1, 2015
The Washington Monthly Quotes Lynn L. Bergeson on TSCA Reform Bill
Lynn L. Bergeson was quoted in “Pick Your Poison,” an article in the Summer 2015 Washington Monthly discussing Toxic Substances Control Act (TSCA) modernization.
In the absence of appropriate federal protections, states have stepped into the breach, promulgating their own rules. Under current TSCA regulations, unless and until the EPA regulates a chemical, states can issue their own limits. Those that have done so include California, New York, Vermont, Washington, Massachusetts, and Maryland. Among the many rules are New York’s ban on children’s goods that contain ... read more >
May 27, 2015
BNA Daily Environment Report Includes B&C Analysis in Article on TSCA Modernization Act
The May 27, 2015, Bloomberg BNA Daily Environment Report article “TSCA Modernization Act Introduced in House; Key Republicans, Democrats Back Legislation,” included quotes from the B&C analysis “TSCA Reform: Detailed Review of Representative Shimkus' Second Discussion Draft of TSCA Reform Legislation.”
Time remains to address pragmatic implementation concerns in the House's “almost surgical” TSCA-reform bill as well as the more expansive Senate bill, the Frank R. Lautenberg Chemical Safety for the 21st Century Act (S. 697), the law firm ... read more >
April 7, 2015
Oil Price Information Network Features Richard E. Engler, Ph.D., in "TSCA Nomenclature May be Barrier for Advanced Biofuels"
The Oil Price Information Network (OPIS) spoke with Richard E. Engler, Ph.D. , Senior Policy Advisor for Bergeson & Campbell, P.C., regarding the application of the Toxic Substances Control Act (TSCA) to oils made from algae feedstocks and other non-traditional bio-materials. The resulting article in the OPIS Ethanol & Biodiesel Newsletter is reprinted below, with permission from OPIS.
TSCA Nomenclature May Be Barrier for Advanced Biofuels
Any number of complications could trip up the commercial use of an advanced biofuel, but one that should ... read more >
April 7, 2015
BNA Daily Environment Report Coverage of Science & the Congress Briefing Quotes Lynn L. Bergeson
The April 7, 2015, Bloomberg BNA Daily Environment Report story "Innovation Outpacing Regulatory Systems; Modernized TSCA, New Data Said to Help," reported on "21st Century Understanding of Chemicals," a congressional briefing hosted by the American Chemical Society (ACS) Science & the Congress Project. Lynn L. Bergeson’s comments at the congressional briefing were quoted.
The Environmental Protection Agency has taken eight times longer to approve new nanoengineered chemicals than new chemicals made with traditional technologies and feedstocks, an attorney specializing in ... read more >
March 30, 2015
BNA Daily Environment Report Special Report Quotes James V. Aidala
In the March 30, 2015 BNA Daily Environment Report Special Report “Questions About Fees, Hiring Staff Among Issues Raised by TSCA Reform Bills,” a reporter spoke with James V. Aidala , Senior Government Consultant with B&C and former Assistant Administrator for EPA's Office of Prevention, Pesticides, and Toxic Substances (OPPTS) (now the Office of Chemical Safety and Pollution Prevention).
To secure money from the fees, the EPA’s chemicals office will have to figure out the costs of the services it would provide to comply with requirements in TSCA reform bills ... read more >
January 14, 2015
Lynn L. Bergeson Referenced In Bloomberg BNA Daily Environment Report Article “Updating TSCA, Spurring Safer Chemicals, Increasing Markets Among Priorities in 2015”
Comments made by Lynn Bergeson were published by Bloomberg BNA Daily Environment Report in an article about recent and continuing efforts to pass a Toxic Substances Control Act (TSCA) reform bill.
Federal preemption of state chemical regulation purposely was not addressed in a widely circulated draft revision of S. 1009 that never was introduced, and the preemption issue remains a challenge, Lynn Bergeson, managing partner of Bergeson & Campbell P.C., told Bloomberg BNA in an e-mail.
The circulated draft did, however, include deadlines for the Environmental Protection Agency to ... read more >
January 9, 2015
Lynn L. Bergeson Quoted In Inside EPA Article "Despite GOP Gains, Preemption Remains Hurdle For TSCA Reform"
Inside EPA featured comments made by Lynn L. Bergeson in an Inside EPA article on issues impacting TSCA reform:
Lynn Bergeson, of the Washington, DC, firm Bergeson & Campbell, noted that the “rights of states need to be part of the discussion on preemption in reform talks during the next Congress,” adding that the importance of the issue “cannot be overestimated’ in securing approval of a TSCA reform ... read more >
November 12, 2014
Lynn L. Bergeson Quoted in Chemical Watch Story "Republican Control of Congress Boosts TSCA Reform Prospects"
Chemical Watch quoted Lynn L. Bergeson in a November 12, 2014, article about the effects of a Republican-controlled Congress. “’Given the Republican gains in the Congress, one scenario would be a strong effort to push through the Udall-Vitter proposal,’ said Lynn Bergeson of the law firm Bergeson & Campbell. If Mr Inhofe becomes the chair of the EPW Committee, ‘trying to make discussion, using this proposal as a starting point, makes sense’, she ... read more >
November 7, 2014
Key Presentations, Video Clips, and Daily Reports from ChemCon The Americas 2014
New ABA book edited by Lynn L. Bergeson, Global Chemical Control Handbook, Announced at Conference
ChemCon the Americas 2014 brought together an international audience of over 200 industry, regulatory, and policy leaders in Chicago, Illinois, October 27-31, 2014, to go in-depth on virtually every major chemical regulatory issue worldwide. Speakers included Mike Rasenberg of the European Chemicals Agency (ECHA), Dr. Jeffrey Morris of the U.S. Environmental Protection Agency (EPA), Dan Bastien of Environment Canada, Qiang Liu of the Chinese State Administration of Work Safety (SAWS), ... read more >
October 31, 2014
Bergeson & Campbell P.C. Quoted in Inside EPA Story "EPA Readies New Chemical Risk Analyses As TSCA Reform Prospects Fade"
Inside EPA quoted an October 23, 2014, email commentary from Bergeson & Campbell P.C.® discussing the effectiveness of the Toxic Substances Control Act Work Plan. The Work Plan "reflects a certain nimbleness and elasticity in the program, features that are essential to the success of any chemical assessment process,” said the email. "The update also speaks favorably of the Work Plan's ability to accommodate new information and recalibrate on an ongoing basis. . . . Although TSCA reform legislation was not in the cards for this Congressional session, it is good to ... read more >
October 3, 2014
Lynn L. Bergeson Quoted in Law360 Article "TSCA Reform Chances Dim With Boxer's Preemption Pushback."
Lynn L. Bergeson was quoted in Law360 discussing the recently released proposals to update the Toxic Substances Control Act (TSCA). “‘Electing to eliminate any preemptive effect virtually assures the propagation of inconsistent, random state and local chemical regulations,’ Lynn Bergeson, managing partner of Bergeson & Campbell PC, said. ‘The patchwork approach to state and local regulations is the nemesis of the business community and a key driver for TSCA reform.’ Bergeson said there is not much room for negotiation under Boxer’s ... read more >
September 25, 2014
Lynn L. Bergeson quoted in Bloomberg BNA Daily Environment Report Story "Senate TSCA Modernization Talks Collapse; Reform Supporters Look to Next Congress."
The September 19, 2014, Bloomberg BNA Daily Environment Report featured comments by Lynn L. Bergeson regarding the collapse of the Toxic Substances Control Act (TSCA) reform talks, specifically efforts to revise the Chemical Safety Improvement Act (S. 1009). Bergeson “told Bloomberg BNA the collapse of the bipartisan Senate discussions on TSCA reform was disappointing but not surprising. ‘Stakeholders can be encouraged by the late rally in the legislative cycle, and perhaps by whatever progress was made to move the needle closer to a version of reform legislation that both ... read more >
September 18, 2014
Lynn L. Bergeson comments on TSCA reform in Chemical Watch article "US Senator Boxer Reveals TSCA Reform Bill: Vitter Proposal Roundly Criticised."
Chemical Watch quoted Lynn L. Bergeson in response to Senator Boxer’s (D-CA) Toxic Substances Control Act (TSCA) counterproposal to the Chemical Security Improvement Act (CISA) sponsored by Senator David Vitter (R-LA). Bergeson said of the issue “I do not give Senator Boxer’s bill, or any other TSCA reform measure much hope given the lateness of the session, the lack of alignment on key measures in the bill, and the polarisation on matters generally in Congress. Whether the bill provides a useful jump start to discussion next session is another matter.” Bergeson additionally stated ... read more >
August 3, 2014
InsideEPA Features Blog Post by Lynn L. Bergeson, Stirs Response and Debate
In “TSCA Reform: Dead for Now,” Lynn L. Bergeson’s July 18th post on the American College of Environmental Lawyers blog, Ms. Bergeson shared the following thoughts:
“Despite high hopes earlier this year for the promise of a legislative make-over, Toxic Substances Control Act (TSCA) reform measures are dead, certainly for the remainder of this Congressional session and possibly the next. In the category of all things happen for a reason, maybe there is a silver lining to this disappointing result.
“TSCA is among the oldest federal environmental laws, one of ... read more >
June 6, 2014
Most Agree More Money Needed for TSCA; How Much, for What, Remain Unclear
Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson and B&C affiliate Charles Auer in a Special Report on TSCA Reform published today.
“Charles Auer, a consultant who led TSCA implementation throughout most of his 32-year career at the EPA, agreed it will be challenging to resolve the many valid questions that would arise on user fees. It would be unwise, however, to continue to ignore the question of funding in TSCA reform discussions, he said. ‘It’s always been the elephant in the room,’ Auer said. The number of questions Republicans and Democrats ... read more >
June 5, 2014
Inside EPA features B&C commentary in "Democrats' Proposed Amendment Widens Gap In House TSCA Reform Effort."
“While the Democrats' changes seek to address many concerns Jones and environmentalists have raised, the redline avoids addressing the issue of whether and to what extent a new federal chemicals management law should preempt state regulation of industrial chemicals. The issue has become particularly fraught in the Senate, where Environment and Public Works Committee Chairman Barbara Boxer (D-CA) has made protection of California's extensive chemical regulations in the Senate bill a prerequisite of her support. The House Democrats' redlined draft bill simply says, ‘Strike [Republicans'] ... read more >
April 3, 2014
ABA Section on Environment, Energy, and Resources Releases Five White Papers Regarding TSCA Reform
The American Bar Association's (ABA) Section on
Environment, Energy, and Resources (SEER) has issued
five white papers designed to assist stakeholders in the
ongoing debate to reform the Toxic Substances Control
Act (TSCA). The papers are on the following
TSCA-related topics:
Overview of TSCA
Trade Secret and Confidential Business Information
Briefing Paper
Preemption of Private Rights of Action Under TSCA
and TSCA Legislation Briefing Paper
Standard for Taking Regulatory Action Under TSCA
("Safety Standard") Briefing Paper
Preemption of State Laws and Regulations Briefing ... read more >
January 16, 2014
US Chemical Leak Refocuses Attention on TSCA Adequacy
Lynn L. Bergeson was quoted in a Chemical Watch article on the chemical spill near Charleston, West Virginia: “The spill ‘provides a textbook example of what's wrong with [TSCA],’ says Lynn Bergeson of the law firm Bergeson and Campbell. ‘The paucity of information is the sticking point,’ she says, adding that public officials need access to more data than is currently ... read more >
May 29, 2013
B&C®'s Analysis of the Vitter/Lautenberg TSCA Reform Bill Featured in Inside EPA
Inside EPA featured B&C®’s commentary in an article titled “Early Concerns Hint At Senate Debate Over Bipartisan TSCA Reform Bill.” Read the full commentary, “The Chemical Safety Improvement Act: An In-Depth Review and Analysis,” ... read more >
May 24, 2013
Senate Committee on Environment and Public Works Quotes Charles M. Auer's Comments on TSCA Reform Legislation
Charles M. Auer, former Director of the U.S. Environmental Protection Agency's Office of Pollution Prevention and Toxics, which is responsible for the implementation of the Toxic Substances Control Act (TSCA), was quoted in a press release issued yesterday by the Senate Committee on Environment and Public Works regarding the introduction of S. 1009, the Chemical Safety Improvement Act, historic bi-partisan TSCA reform legislation. Charlie is affiliated with Bergeson & Campbell, P.C. and its consulting affiliate The Acta Group. The press release including a link to the full text of ... read more >
April 12, 2013
Lautenberg Reintroduces TSCA Reform Bill Absent GOP Support
Pesticide and Chemical Policy quoted Lynn L. Bergeson in their April 12, 2013 Daily News Alert article on the reintroduced Safe Chemicals Act: “The Lautenberg bill is “the same as it ever was ... and offers no changes from what was passed," says Lynn Bergeson. "It is discouraging there is nothing new." But something new could be coming soon, specifically a Republican proposal to revamp TSCA from Sen. David Vitter (R-LA), the ranking member of the EPW committee. Details have been few and far between, but Vitter has been working on a proposal since the fall (See ... read more >
February 15, 2013
EPA Studies, California Rules May Guide “Risk” Level Absent TSCA Reform
The February 15, 2013, issue of Inside EPA quoted Lynn L. Bergeson extensively. “In lieu of reform legislation clearing Congress, Lynn Bergeson, a TSCA attorney and owner of law firm Bergeson & Campbell, told a recent legal conference that industry lawyers should be closely watching the agency’s first batch of five draft risk assessments, released last month, given that they could serve as an early indication of how EPA’s toxics office will handle risk analyses of existing chemicals — which are currently ‘grandfathered’ under TSCA. The assessments ... read more >
February 14, 2013
Change of Leadership on Senate Environment and Public Works Subcommittee Unlikely to Affect TSCA Reform Efforts
The February 14, 2013, issue of Bloomberg BNA Daily Environment Report notes Lynn L. Bergeson “anticipates Lautenberg’s move will not affect the TSCA-reform debate,” in the article “Lautenberg Stepping Down as Chairman Of Panel With TSCA, Superfund Jurisdiction.” “Lautenberg is still a champion of TSCA reform, and will no doubt continue to push for reform. Whether that happens any time soon continues to be doubtful given the lack of movement in the House. Whether a Vitter TSCA bill will jump start the TSCA debate is also unclear, but it should certainly ... read more >
June 24, 2011
Bipartisan Senate TSCA Reform Talks Spur Queries on Lack of EPA Role
The June 24, 2011, issue of Inside EPA quotes Bergeson & Campbell, P.C.'s June 16, 2011, memorandum regarding bipartisan Senate talks concerning reform of the Toxic Substances Control Act ... read more >
June 13, 2011
Support Continues for TSCA Reform, But Consensus on Approach Remains Elusive
The June 13, 2011, issue of BNA Daily Environment Report quotes James V. Aidala regarding the current status of reform of the Toxic Substances Control Act ... read more >
May 9, 2011
Photo: TSCA Reform Webinar
Photo taken during the May 9, 2011 TSCA Reform Webinar. Pictured :
Dr. Richard A. Denison, Environmental Defense Fund, Inc.
Jim Aidala, Senior Government Consultant, Bergeson & Campbell, P.C.
Andy Ingrejas, National Campaign Director, Safer Chemicals, Healthy Families
Lynn L. Bergeson, Bergeson & Campbell, ... read more >
April 29, 2011
TSCA Reform Webinar Invitation : S. 847—Lautenberg’s TSCA Reform Bill
Monday, May 9, 2011 1:00 p.m. - 3:00 p.m. (EDT)
Bergeson & Campbell, P.C. (B&C), B&C Consortia Management, L.L.C. (BCCM), The Acta Group, L.L.C. (Acta), and The Acta Group EU, Ltd (Acta EU) are hosting a free webinar to discuss Senator Frank R. Lautenberg's (D-NJ) recently introduced bill, S. 847, the Safe Chemicals Act of 2011, a bill to amend the Toxic Substances Control Act (TSCA).
This webinar will focus on S. 847; identify and discuss key differences between it and S. 3209, Senator Lautenberg's bill of the same name to amend TSCA introduced last year; and ... read more >
February 4, 2011
Lautenberg Seeks Bipartisan Help with TSCA Reform
The February 4, 2011, issue of Pesticide & Chemical Policy includes an article quoting Lynn L. Bergeson regarding the opportunity for industry to drive Toxic Substances Control Act (TSCA) reform ... read more >
January 28, 2011
Advocates Say TSCA Reform Could Reduce Children's Cancer Risk from Chemical Exposures
In a January 28, 2011, article, Pesticide & Chemical Policy quotes James V. Aidala regarding the possibility of Toxic Substances Control Act (TSCA) reform legislation passing in the 112th ... read more >
November 9, 2010
TSCA Reform—What Are Its Chances?
ChemCon Daily quotes Lynn L. Bergeson regarding the effect of the mid-term elections on reform of the Toxic Substances Control Act ... read more >
November 5, 2010
Republican Gains Could Dim Prospects for TSCA Reform, Increase Scrutiny of EPA Programs
The November 5, 2010, issue of Pesticide & Toxic Chemical News quotes Lynn L. Bergeson regarding the effect of the mid-term elections on reform of the Toxic Substances Control Act ... read more >
October 22, 2010
TSCA Reform Concerns Remain, But Focus Shifts to Ongoing Regulatory Actions
The October 22, 2010, issue of Pesticide & Toxic Chemical News quotes Lynn L. Bergeson regarding the provisions of the Toxic Substances Control Act (TSCA) reform ... read more >
August 13, 2010
Former EPA Toxics Chief Doubts Workability Of House TSCA Reform Bill
The August 13, 2010, issue of Inside EPA discusses the testimony submitted by Charlie Auer to the House Committee on Energy and Commerce Subcommittee on Commerce, Trade and Consumer Protection on the House Toxic Substances Control Act (TSCA) reform legislation (H.R. ... read more >
June 1, 2010
Use of dispersants in Gulf points to need for TSCA reform, critics say
The May 31, 2010, issue of Pesticide & Toxic Chemical News quotes Jim Aidala regarding how proposals to reform the Toxic Substances Control Act would affect confidential business ... read more >
May 4, 2010
TSCA Reform Bill Could Target Broad List Of Manufacturers, Industry Fears
The May 4, 2010, issue of InsideEPA.com's Daily News references Bergeson & Campbell, P.C.'s April 27, 2010, analysis of the TSCA reform ... read more >
May 3, 2010
TSCA Reform Proposals Said to Broaden Scope of Firms Required to Provide EPA Data
In the May 3, 2010, issue of BNA Daily Environment Report, Kathleen Roberts notes that the proposed Toxic Substances Control Act (TSCA) reform legislation would make a critical change by covering manufacturers "and" processors. Currently, most TSCA provisions apply to manufacturers "or" processors, and the U.S. Environmental Protection Agency (EPA) has rarely chosen to seek toxicity and other data from ... read more >
April 23, 2010
Industry Fears TSCA Reform Bill Could Stymie New Chemical Development
In an April 23, 2010, issue of Inside EPA, Charles M. Auer is quoted regarding the data requirements for new and existing chemicals under the Toxic Substances Control Act (TSCA) reform legislation. According to Auer, the Senate bill has a "significant bias" against the development of new chemicals, because data for new substances would be required upfront, while manufacturers could have years to submit the same data for existing ... read more >
April 19, 2010
TSCA Reform Discussions Must Include Logistical Issues, Former EPA Staff Say
The April 19, 2010, issue of BNA Daily Environmental Report quotes Charles M. Auer, former Director of the U.S. Environmental Protection Agency's (EPA) Office of Pollution Prevention and Toxics (OPPT), and James V. Aidala, former EPA Assistant Administrator for Prevention, Pesticides, and Toxic Substances, regarding the Toxic Substances Control Act (TSCA) reform legislation released by ... read more >
January 22, 2010
TSCA Reform Debate, Increased EPA Scrutiny Of Chemicals Predicted Throughout 2010
The January 22, 2010, issue of BNA Daily Environment Report quotes Lynn L. Bergeson regarding the promulgation of a general significant new use rule for nanoscale chemical substances. According to Bergeson, it “has appeal as it would obviate the need for a TSCA Section 8(a) rule and avoid the small business exemption.” Bergeson also commented on nanomaterial developments expected in ... read more >
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2200 Pennsylvania Avenue, NW, Suite 100W
Washington, D.C. 20037
202-557-3800 • 202-557-3836 (fax) | lawbc.com
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