Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “TSCA asbestos proposal to put cost-benefit considerations under the microscope”

On May 20, 2022,  Richard E. Engler, Ph.D., Director of Chemistry with Bergeson & Campbell, P.C. (B&C^®), was quoted by Chemical Watch regarding the U.S. Environmental Protection Agency’s (EPA) proposal to ban all ongoing uses of chrysotile asbestos, including a two-year deadline for the chlor-alkali industry to stop using asbestos diaphragms in the production of chlorine.

The 12 April proposal – the first issued under the amended TSCA in response to a completed risk evaluation – floats what the agency calls an “aggressive transition” away from ongoing uses of chrysotile asbestos, including a two-year deadline for the chlor-alkali industry to stop using asbestos diaphragms in the production of chlorine.

“I was surprised at how abbreviated the timeline for phase-out is,” said Richard Engler, director of chemistry at Bergeson & Campbell, a law firm that assists companies with TSCA compliance. “It is not clear that the chlor-alkali industry can meet the proposed timeframe.”

[…]

In Dr Engler’s view, replacing domestic production with foreign import of chlorine “is a much greater risk than continued production with asbestos diaphragms”.

[…]

Dr Engler said the agency “appears to have not focused as much as it should have on its assessment of the costs or time to transition to the membrane alternative.” He also did not see “a particularly compelling justification” for adopting a ban instead of an exposure limit.

See – https://chemicalwatch.com/486953/tsca-asbestos-proposal-to-put-cost-benefit-considerations-under-the-microscope (subscription required)