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 Engler, who became chemistry director at the Washington office of Bergeson & Campbell PC after leaving the EPA.

Many consent orders include restrictions limiting how far down the supply chain a new chemical can be sold until SNURs are issued, he said.

Once the SNURs are proposed, the new chemicals can be sold further down the supply chain.

See - https://bnanews.bna.com/environment-and-energy/more-sales-broader-safeguards-may-follow-chemical-rule-deluge (subscription required)