2011 Predictions For EPA's Office Of Chemical Safety And Pollution Prevention: Bergeson & Campbell, P.C.'s (B&C) thoughts on what may be headed our way in 2011 from the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP) are provided in a memorandum available online. In short, the general trends established by the Obama Administration during the past two years are expected to continue notwithstanding the 2010 election results....
In response to concerns vigorously expressed by diverse stakeholders over the final draft of the Safer Consumer Product Alternatives (SCPA) Regulations, the California Environmental Protection Agency (CalEPA) has effectively delayed implementation of the much-anticipated regulations.
December 31, 2010
Lynn L. Bergeson, “The Proposed TSCA Inventory Update Reporting Rule: Big Changes Are in Store,” Environmental Quality Management, Winter 2010.
While debate continues to swirl around whether, and to what extent, the Toxic Substances Control Act (TSCA) needs retooling, just about everyone agrees that the U.S. Environmental Protection Agency (US EPA) needs more information on chemical production, use, and exposure in order to make informed decisions about chemical risk management. Most also agree that TSCA could be put to greater use for these purposes.
December 31, 2010
Lynn L. Bergeson, “Revisions to the ‘Green Guides’,” Pollution Engineering, December 2010.
Early in October, the Federal Trade Commission (FTC) released important revisions to its Guides for the Use of Environmental Marketing Claims (Green Guides) to make them easier for companies to use and understand.
December 30, 2010
Automotive Groups Challenge Restrictions on Refrigerant, Say EPA Limits Unsupported
The December 30, 2010, issue of BNA Daily Environment Report quotes Lynn L. Bergeson regarding the U.S. Environmental Protection Agency's significant new use rule (SNUR) for the refrigerant known as HFO-1234yf. According to Bergeson, the final rule was based on an entirely new risk assessment and data first made available for review when the SNUR was issued on October 27, 2010, meaning EPA promulgated the SNUR without adequate notice and comment, in violation of the Administrative Procedure...
The U.S. Environmental Protection Agency’s (EPA) December 20, 2010, Regulatory Agenda includes several notices concerning nanoscale materials: Test Rule for Certain Nanoscale Materials — EPA states that it is developing a test rule under Section 4(a) of the Toxic Substances Control Act (TSCA) to require manufacturers (defined by statute to include importers) and processors of the multiwall carbon nanotube described in Premanufacture Notice (PMN) P-08-199, certain clays (e.g., kaolin...
December 28, 2010
Australia Issues Guidance on New Chemical Requirements for Notification of Industrial Nanomaterials
Australia’s National Industrial Notification and Assessment Scheme (NICNAS) recently issued guidance on the new chemical requirements for the notification and assessment of industrial nanomaterials that are considered to be new chemicals. The new administrative arrangements will be effective from January 1, 2011, and will apply to any new chemical that falls under the following working definition of “industrial nanomaterial”: . . . industrial materials...
The California Department of Toxic Substances Control (DTSC) released a December 23, 2010, letter from Linda S. Adams, California's Secretary for Environmental Protection to Assembly Member Mike Feuer, the author of the 2008 law (A.B. 1879) that would require regulations to address chemicals and chemical ingredients in consumer products. In the letter, Secretary Adams responded to Feuer's letter outlining his concerns about the DTSC's November 16, 2010, release of revisions to its "Safer...
The Switzerland State Secretariat for Economic Affairs (SECO) has posted a December 21, 2010, guidance document for preparing safety data sheets (SDS) for synthetic nanomaterials. Safety Data Sheet (SDS): Guidelines for Synthetic Nanomaterials is intended to demonstrate the information necessary to ensure the safe handling of nano-objects and products that contain nano-objects; offer assistance on how the relevant information can be identified and in which form and which place...
December 22, 2010
CDTSC Issues DCI for Nano Metals, Nano Metal Oxides, and Quantum Dots
On December 21, 2010, the California Department of Toxic Substances Control (CDTSC) issued a data call-in (DCI) for information regarding analytical test methods, and other relevant information, from manufacturers of nano silver, nano zero valent iron, nano titanium dioxide, nano zinc oxide, nano cerium oxide, and quantum dots. According to CDTSC, Health and Safety Code Section 57018(a)(4) defines a “manufacturer” as a “person who produces a chemical in this state or imports a chemical...