B&C News: TSCA

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 >
February 8, 2018
Lynn L. Bergeson Named Vice Chairman of Newly Formed IBA Agriculture Law Committee
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Lynn L. Bergeson has been appointed Vice Chairman of the Agriculture Law Committee (ALC) at the International Bar Association (IBA). Ms. Bergeson, Managing Partner of B&C and President of Acta, will serve a two-year term.   The IBA is the world’s leading organization of international legal practitioners, bar associations, and law societies, promoting an exchange of information among legal associations worldwide. The Agricultural Law Section joins a wide range of legal ... read more >
February 2, 2018
Bloomberg BNA Daily Environment Report Article Quotes Lynn L. Bergeson Regarding EPA Data Submissions
On February 2, 2018, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “Chemical Makers Send Limited Exposure Data to EPA as Deadline Nears.” Companies’ failure to provide more data wasn't “all that surprising as value chain challenges make it very difficult to populate these files with a lot of user information,” Lynn Bergeson, managing partner at the law firm Bergeson & Campbell PC, told Bloomberg Environment. See - ... read more >
January 25, 2018
TSCA Reform Implementation Seminar: Impacts and Best Practices for the New Chemicals Law
  Wednesday, February 7, 2018 1:30 p.m. - 4:30 p.m. (EST)   Register Today   Bergeson & Campbell, P.C. (B&C®) is pleased to participate in the upcoming “TSCA Reform Implementation Seminar:  Impacts and Best Practices for the New Chemicals Law,” presented by the Michigan Chemistry Council.  This valuable seminar features a panel of industry practitioners, as well as talented legal experts including Lynn L. Bergeson, Managing Partner of B&C, who will present on Toxic Substances Control Act (TSCA) implementation and upcoming activities, as ... read more >
January 19, 2018
WEBINAR - - Chemical Regulation in 2018: A Sneak Preview of Things to Come
  Thursday, February 8, 2018 12:30 p.m. - 1:30 p.m. (EST) Register Today First in the 2018 Bloomberg BNA/Bergeson & Campbell, P.C. Chemical Policy Summit Series -- see the full schedule of webinars below. What a difference a year makes!  To some extent, the surprise of 2016 -- the election of Donald J. Trump as President -- did make many predicted changes about life in Washington, D.C. for 2017 come true.  The U.S. Environmental Protection Agency’s (EPA) budget proposal reflects serious cuts, environmental policies were reversed, rules were withdrawn, several ... read more >
January 18, 2018
Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environment Report Article “Citizens Petitions, Lawsuits on Chemical Rules Likely to Grow”
On January 18, 2018, Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), was quoted in a Bloomberg BNA Daily Environment Report article regarding an increase in citizen group petitions as a result of Toxic Substances Control Act (TSCA) Reform.  Chemical manufacturers should expect to see more petitions from citizen groups asking the EPA to regulate substances now that the nation's primary chemicals law has been amended, attorneys tell Bloomberg Environment. Environmental, animal welfare, and other organizations will likely use every provision allowed ... read more >
January 17, 2018
Richard E. Engler, Ph.D., Quoted by NBC News Regarding Changes to EPA’s New Chemical Assessments
On January 17, 2018, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted by NBC News in the article “EPA eases path for new chemicals, raising fears of health hazards.” The EPA’s new approach is likely to reduce the testing that manufacturers who first bring these new chemicals to market are required to do. Using significant new-use rules (SNURs) “reduces the testing that the EPA is seeking to impose, because testing is rarely required in a SNUR,” said Richard Engler, a former EPA scientist ... read more >
January 10, 2018
Bloomberg BNA Daily Environment Report References NCC Response in “Environmentalists Challenge Safety of EPA's New Chemical Reviews”
On January 10, 2018, the Bloomberg BNA Daily Environment Report covered the TSCA New Chemicals Coalition’s (NCC) response to a federal court challenge by the Natural Resources Defense Council (NRDC) against the U.S. Environmental Protection Agency's (EPA) New Chemicals Decision-Making Framework. The New Chemicals Coalition, which Bergeson & Campbell P.C. launched in 2017 as a forum for companies interested in bringing new chemicals to market, has not decided whether or not it will intervene. The firm will continue to track the case, Lynn Bergeson, managing partner ... read more >
January 4, 2018
TSCAblog™ Post Quoted in “Fluoride Case Ruling May Open Door To More TSCA Petitions, Attorneys Say”
On January 4, 2018, the TSCAblog™ post “In Case of First Impression, Court Rules EPA Wrongly Dismissed Citizen Group’s TSCA Section 21 Petition” was quoted by Inside EPA in an article discussing the U.S. Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA) Section 21 ruling on flouride.  The law firm Bergeson & Campbell describes the ruling as a “fairly scathing rebuke of EPA’s legal positions,” in a Dec. 22 blog post, adding that it “essentially rejected EPA’s interpretation that a citizen petition ... read more >
December 15, 2017
Chemical Watch Quotes the TSCA New Chemicals Coalition in “Industry group: US EPA should cede workplace hazard regulation to Osha”
On December 15, 2017, Chemical Watch featured comments by the TSCA New Chemicals Coalition (NCC) on the U.S. Environmental Protection Agency’s (EPA) new chemical evaluation policy. An industry group has argued that the US EPA should avoid issuing orders to mitigate workplace risks associated with new chemicals. Instead, it says, it should turn over that regulatory responsibility to the Occupational Health and Safety Administration (Osha). The TSCA New Chemicals Coalition (NCC), a group of companies represented by the law firm Bergeson & Campbell, hopes to build on a provision in ... read more >
December 11, 2017
Richard E. Engler, Ph.D., Quoted in Chemical Watch “OPPT director defends US agency plans for new chemical evaluation”
On December 11, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted in Chemical Watch regarding concerns with the U.S. Environmental Protection Agency’s (EPA) plan to move away from consent orders in favor of Significant New Use Rules (SNURs) when regulating potential uses of new chemicals. When the situation described in a pre-manufacture notice (PMN) is not of concern, but there is a potential use of the new chemical that would raise risk concerns, the EPA used to issue consent orders restricting how it can be used, followed by ... read more >
December 11, 2017
Comments by Lynn L. Bergeson Regarding TSCA Implementation under the Trump Administration Featured in Chemical Week
On December 11, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted in the Chemical Week article “Trump's EPA: TSCA remains priority amid regulatory rollback.” “Not surprisingly, there’s been a tremendous focus on the implementation requirements for Lautenberg,” says Lynn Bergeson, managing partner of Bergeson & Campbell (Washington, DC). Efforts have included building a conceptual framework of how to review and apply the new standards under key sections that cover manufacturing and process notices; how ... read more >
November 29, 2017
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted in Bloomberg BNA Daily Environment Report Article “Manufacturers Gain Insight into EPA Reviews of New Chemicals"
On November 29, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Senior Chemist at B&C, were quoted by Bloomberg BNA Daily Environment Report regarding recently released U.S. Environmental Protection Agency (EPA) documents on new chemical review procedures. The Points to Consider When Preparing TSCA New Chemical Notifications document, in particular, provides a clear, useful summary of the agency's current practice, said Lynn Bergeson, managing partner in the Washington office of Bergeson & Campbell, ... read more >
October 26, 2017
B&C Authors Contribute to The Evolving Landscape of TSCA Reform Implementation Published by Bloomberg BNA
Bergeson & Campbell, P.C. (B&C®) is pleased to inform our clients and friends of the publication by Bloomberg BNA of EHS Strategies:  The Evolving Landscape of TSCA Reform Implementation, the latest edition of BNA’s quarterly EHS Strategies report.  The report provides a comprehensive analysis of recent Toxic Substances Control Act (TSCA) developments written by many of the key players in the development, passage, and implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). B&C Managing Partner Lynn L. Bergeson, Senior ... read more >
September 22, 2017
Inside EPA Quotes B&C TSCAblogTM in Article Regarding Rejected TSCA Section 21 Fluoride Petition
On September 22, 2017, Inside EPA quoted the post “EPA Denies TSCA Section 21 Petition on Fluoride Chemicals in Drinking Water; Provides Response to Petition,” from Bergeson & Campbell, P.C.’s (B&C®) TSCAblogTM in the article “Suit Over Rejected Fluoride Petition Could Test EPA's Stance On TCSA 'Uses'.” Observers tracking EPA's implementation of the new TSCA law said last spring shortly before the suit was filed that it would provide a test case for the agency's interpretation that petitioners must provide a ... read more >
September 12, 2017
Chemical Watch Quotes Lynn L. Bergeson In Article Regarding B&C’s TSCA New Chemicals Coalition
On September 12, 2017, Chemical Watch quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), in the article “US EPA pilots new pre-manufacture notice guidelines.” [T]he law firm Bergeson & Campbell has formed the TSCA New Chemicals Coalition which is intended to give the chemical community greater opportunity to engage with EPA on constructive improvements to the new chemical review process. "About 50 companies so far have expressed interest in joining the coalition," said the firm's managing partner Lynn Bergeson. "One ... read more >
September 1, 2017
Richard E. Engler, Ph.D., Quoted in Bloomberg BNA Daily Environment Report Article “Fate of Chemical Makers’ Trade Secrets Rests With EPA”
On September 1, 2017, Richard E. Engler, Ph.D., Senior Chemist with Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg BNA Daily Environment Report regarding how Confidential Business Information (CBI) claims would be handled by the U.S. Environmental Protection Agency (EPA) under the New Toxic Substances Control Act (New TSCA). The 2016 update to the Toxic Substances Control Act added a new requirement that manufacturers routinely justify their need for that chemical information to be kept confidential. The statute requires the EPA to review all claims that a ... read more >
August 28, 2017
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Paper Waste Spurs Testing of Low-Cost Carbon Fiber for Products”
On August 28, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Report discussing Toxic Substance Control Act (TSCA) regulatory concerns for carbon fiber with a lignin. Since the lignin-PAN carbon fiber under development does not yet involve the use of carbon nanofibers, Washington State University's Ahring said the product will not require clearance under [TSCA]. But some worry that the enthusiasm supporting the rapid commercialization of biobased chemicals has gotten out in front of potential ... read more >
August 23, 2017
Inside EPA Covers The Formation Of B&C’s New “TSCA New Chemicals Coalition”
On August 23, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA in the article “New Industry Coalition Launched On TSCA New Chemicals Review Issues.” For further information on joining the coalition, call or e-mail Lynn L. Bergeson at 202-557-3801 or lbergeson@lawbc.com. Bergeson & Campbell, a law firm that specializes in chemical industry issues, is creating a coalition of companies to craft uniform comments to EPA on industry concerns that have arisen with the agency’s process for reviewing ... read more >
August 16, 2017
Scientific American Quotes Lynn L. Bergeson Regarding EPA’s New Framework Rules for TSCA
On August 16, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by Scientific American in “Trump’s EPA May Be Weakening Chemical Safety Law.” The [U.S. Environmental Protection Agency (EPA)] and industry leaders dispute that the framework rules undermine [the Toxic Substance Control Act (TSCA)]. “I thought they were clearer, cleaner and more focused,” says Lynn Bergeson, a lawyer whose firm Bergeson & Campbell specializes in chemical issues. She adds the new rules will result in a “better use of ... read more >
August 15, 2017
Lynn L. Bergeson Quoted In “EPA TSCA Guide May Give Industry New Strategies For Risk Evaluations”
On August 15, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®) was quoted by Inside EPA discussing how new U.S. Environmental Protection Agency (EPA) risk evaluation guidelines may impact industry. “My sense is that if you have a promising chemical product and wish to get it through the risk evaluation process sooner rather than later, considering this option makes sense,” Lynn Bergeson, managing partner of environmental law firm Bergeson & Campbell, tells Inside EPA. “You control the timing, and might have a better line of ... read more >
August 11, 2017
“TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” Webinar Brings Together Industry and EPA to Talk New TSCA
Bergeson & Campbell, P.C. (B&C®) is pleased to announce that the materials and recording from the “TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” webinar are now available for download. This complimentary webinar, co-hosted with Bloomberg BNA, was presented by a panel including Dr. Jeff Morris, U.S. Environmental Protection Agency (EPA), and former EPA officials and seasoned regulatory professionals who engaged in a lively discussion on: Toxic Substances Control Act (TSCA) Section 5 Inventory notification reporting ... read more >
August 10, 2017
Lynn L. Bergeson Quoted in Chemistry World Article “EPA Clears Chemicals Backlog”
On August 10, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by Chemistry World regarding the U.S. Environmental Protection Agency’s (EPA) “announcement that it has ‘eliminated’ the logjam of 600 new chemicals undergoing review” under the Toxic Substances Control Act (TSCA). Lynn Bergeson, a managing partner with the Washington, DC-based law firm Bergeson & Campbell that advises chemical companies about regulatory compliance, is enthusiastic about the developments. ‘This means that those new ... read more >
August 8, 2017
Bloomberg BNA Daily Environment Report Included Comments by Lynn L. Bergeson and Charles M. Auer on EPA Chemical Backlog
On August 8, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), and Charles M. Auer, Senior Regulatory and Policy Advisor with B&C, were quoted by Bloomberg BNA Daily Environment Report in the article “Clearing EPA's New Chemicals ‘Backlog’ Cheered by Industry.” Lynn Bergeson, managing partner with Bergeson & Campbell, P.C. in Washington, also praised the EPA's progress. That law firm will review EPA's latest statistics to assess the agency's progress completing negotiations it undertakes with chemical ... read more >
August 4, 2017
Bloomberg BNA Daily Environment Report Quotes Richard E. Engler, Ph.D., on EPA’s New Electronic Reporting System
On August 4, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “Chemical Makers Told to Act Now, Duck Regulatory Hassles Later.” Chemical manufacturers should have access to the EPA's electronic reporting system now to avoid headaches in six months as the deadline approaches to notify the agency about chemicals they have made or imported during the past 10 years. The clock hasn't started yet for the 180 days that chemical manufacturers and importers have to ... read more >
August 3, 2017
Charles M. Auer Quoted In “Chemical Risk Review Details Expected From EPA by Fall”
On August 3, 2017, Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg BNA Daily Environment Report discussing U.S. Environmental Protection Agency (EPA) plans to release documents detailing its new Toxic Substances Control Act (TSCA) chemical review process.  The documents are expected to aid companies as they prepare premanufacture notices (PMNs) they must submit when asking the agency to approve a new chemical, Charlie Auer, senior regulatory and policy adviser with Bergeson & Campbell, said. As a ... read more >
July 27, 2017
TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5
Bloomberg BNA/Bergeson & Campbell, P.C. Webinar Wednesday, August 2, 2017, 12:00 p.m. - 1:30 p.m. (EDT) Complimentary Registration Available Online   With the recent release of the 2016 Chemical Data Reporting (CDR) dataset and the initial interim list of active substances released with the June 2017 copy of the Toxic Substances Control Act (TSCA) Inventory (Inventory), the magnitude of effort that will be needed to comply with the Section 8(b)(4) Inventory notification process is becoming clear (see our June 6, 2017, memorandum “Preparing for the Inventory Reset: It Is Not ... read more >
July 19, 2017
"TSCA Reform: One Year Later" Conference Elicits Frank and Productive Discussion from Government, NGO, and Industry Speakers
On June 27, 2017, the Environmental Law Institute (ELI), Bergeson & Campbell, P.C. (B&C®), the Environmental Defense Fund (EDF), and the George Washington University Milken Institute School of Public Health (GWU) held a day-long "TSCA Reform: One Year Later" conference at the GWU campus exploring the federal government’s implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) on the first anniversary of its enactment. Lautenberg significantly amended the Toxic Substances Control Act, and holds the U.S. Environmental ... read more >
July 18, 2017
Charles Auer and Richard Engler, Ph.D., Quoted In Bloomberg BNA Daily Environment Report Article “Chemical Industry Eyes New Chance to Drive EPA Risk Analyses”
On July 18, 2017, Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), and Richard E. Engler, Ph.D., Senior Chemist with B&C, were quoted by Bloomberg BNA Daily Environment Report regarding the U.S. Environmental Protection Agency’s (EPA) data gathering authority. […] The EPA's recent rules don't mention any intention to use the agency's new authority under the amended chemicals law to order companies to provide toxicity or exposure data, Richard Denison, lead senior scientist for the Environmental Defense ... read more >
July 3, 2017
Career Opportunities at B&C
Bergeson & Campbell, P.C. (B&C®) is seeking chemical regulatory attorneys to join our trusted, respected, and highly-experienced team of lawyers, regulatory consultants, scientists, and policy experts.  Positions will be based in our Washington, D.C. office, although telework arrangements may be considered for suitable candidates.  Applicants should be experienced in the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and other domestic and/or international chemical product laws and governance systems. Desired ... read more >
June 29, 2017
Charles Auer Quoted in Inside EPA Article “The Emerging Debate Over New TSCA Rules: 'Achievable' v. 'Lawful'”
On June 29, 2017, Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA in an article regarding Toxic Substance Control Act (TSCA) framework rules and how they should be implemented. His comments were made on June 27, 2017, during an Environmental Law Institute (ELI) conference celebrating the reformed law’s first anniversary. […] Former career EPA toxics chief Charles Auer, now with the law firm Bergeson & Campbell,  […] noted his own disappointment that EPA has yet to exercise its new ... read more >
June 21, 2017
Inside EPA Quotes Lynn L. Bergeson on Challenges to TSCA Framework Rules
On June 21, 2017, Inside EPA quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), in the article “As EPA Issues TSCA's Framework Rules, Bipartisan Law Faces Challenges.” […] Lynn Bergeson, managing partner of the firm Bergeson & Campbell, suggested some concern in EPA's ability to advance use of these new technologies. She too, noted Lautenberg's requirements regarding non-animal testing, including its direction that EPA craft a plan to mange the transition by June 22, 2018. “We find it very important and ... read more >
June 19, 2017
TSCA Reform—One Year Later
June 27, 2017, 9:00 a.m. - 4:45 p.m. (EDT) Milken Institute School of Public Health George Washington University 950 New Hampshire Ave., N.W. 1st Floor Auditorium Washington, D.C. (and via webinar) Register Today This event is free and open to the public. Join the Environmental Law Institute (ELI) and the George Washington University Milken Institute School of Public Health for a day-long conference exploring the federal government’s implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which significantly amended the Toxic Substances Control Act (TSCA), ... read more >
June 14, 2017
Inside EPA Quotes Lynn L. Bergeson in “Scope Of 'Use' In TSCA Revision Seen Driving New Industry Data-Sharing”
On June 14, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA discussing the impacts of a possible requirement by the U.S. Environmental Protection Agency (EPA) to consider all possible use conditions while conducting risk assessments. […] Speaking at a recent seminar on environmental regulation hosted by the Practising Law Institute in New York, NY, attorney Lynn Bergeson said competing calls from industry and environmentalists on whether risk assessments should consider "all" conditions in which a chemical ... read more >
June 12, 2017
Lynn L. Bergeson, Charles M. Auer, and Richard E. Engler, Ph.D., Present during Bloomberg BNA Webinar "Reviewing New Chemicals Under Amended TSCA: Impact on Innovation"
On June 12, 2017, Bloomberg BNA presented the webinar "Reviewing New Chemicals Under Amended TSCA: Impact on Innovation," featuring Charles M. Auer, Senior Regulatory and Policy Advisor at Bergeson & Campbell P.C. (B&C®); Richard E. Engler, Ph.D., Senior Chemist at B&C.; and Lynn L. Bergeson, Managing Partner at B&C; as well as Jeffery Morris, Director, U.S. Environmental Protection Agency (EPA), Office of Pollution Prevention and Toxics; Beth Bosley, President, Boron Specialties LLC; and Robert Mott, Manager, Global Regulatory, Sun Chemical Corporation. After an ... read more >
May 24, 2017
Lynn L. Bergeson Presents “TSCA Implementation and Current U.S. Regulatory Environment” at NIA Webinar
On May 24, 2017, Lynn L. Bergeson, Managing Partner at Bergeson & Campbell, P.C. (B&C®), presented “TSCA Implementation and Current U.S. Regulatory Environment” at the Nanotechnology Industries Association (NIA) webinar: “Toxic Substances Control Act (TSCA) implementation and current US regulatory environment.” Ms. Bergeson’s presentation addressed reformed TSCA (Frank R. Lautenberg Chemical Safety for the 21st Century Act) implementation and the current regulatory environment under the Trump Administration and U.S. Environmental Protection Agency ... read more >
May 23, 2017
Lisa R. Burchi Explains “The New TSCA: Impact on States and Worker Safety Programs” at ORCHSE Strategies, LLC’s Western Occupational Safety and Health Group Meeting
On May 23, 2017, Lisa R. Burchi, Of Counsel with Bergeson & Campbell, P.C. (B&C®), presented “The New TSCA: Impact on States and Worker Safety Programs” at ORCHSE Strategies, LLC’s Western Occupational Safety and Health Group meeting. Ms. Burchi’s presentation addressed the new Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, and its impact on worker safety programs nationwide. Specifically, she discussed the changes in the designation of workers, identified in the new bill as a ... read more >
May 23, 2017
Bloomberg BNA Presents “Reviewing New Chemicals under Amended TSCA: Impact on Innovation” Webinar
  Monday, June 12, 2017, 12:00 p.m. - 1:30 p.m. (EDT)  This webinar has occurred.  Materials and recording provided upon request to B&C clients, associated businesses, and industry members.     Since enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act last June, a logjam of new chemicals under review at the U.S. Environmental Protection Agency (EPA) unable to enter commerce has developed.  EPA’s Office of Pollution Prevention and Toxics (OPPT) is adjusting to new requirements in the 2016 amendments to the nation’s ... read more >
May 18, 2017
Bergeson & Campbell, P.C. and ABA Books Release New TSCA: A Guide to the Lautenberg Chemical Safety Act and Its Implementation
Bergeson & Campbell, P.C. (B&C®) is pleased to announce the publication of New TSCA: A Guide to the Lautenberg Chemical Safety Act and Its Implementation, released today by the American Bar Association (ABA).  This new book is a comprehensive guide to the substantial revisions to the Toxic Substances Control Act (TSCA) occasioned by enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act on June 22, 2016, to produce “new TSCA,” amending and replacing “old TSCA” as of that date.  B&C Managing Partner Lynn L. Bergeson and ... read more >
May 18, 2017
Charles Auer Quoted in “Rate of EPA Chemical Regulation Ramps Up Since Toxics Law Update”
On March 18, 2017, Bloomberg BNA Daily Environment Report quoted Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), explaining how updates to the Toxic Substances Control Act (TSCA) are impacting new chemical regulations. The Environmental Protection Agency has been regulating more new chemicals since the Toxic Substances Control Act was overhauled than it did before, according to a snapshot of its work over the past 11 months. “It's definitely harder to get a new chemical to market,” Charles Auer, a former senior EPA ... read more >
May 17, 2017
Comments By Dr. Richard E. Engler Featured In Bloomberg BNA Daily Environment Report Article On EPA Chemical Review Process
On May 17, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “Pace of EPA New Chemical Reviews Picks Up, Allaying Concerns.” […] The new information, which the agency posted since May 12, shows the EPA has made many more new chemical decisions since TSCA was amended than was publicly known, Richard Engler, a senior chemist with the Bergeson & Campbell, P.C. in Washington told Bloomberg BNA May 16. […] The first website, which had a search ... read more >
May 5, 2017
Comments By Richard Engler Included In Bloomberg BNA Daily Environment Report Article “Chemicals Law Is Top Priority of Trade Group's New Leadership”
On May 4, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg BNA Daily Environment Report discussing the U.S. Environmental Protection Agency’s (EPA) chemical regulation process in response to efforts by the Society of Chemical Manufacturers & Affiliates (SOCMA) to speed up the process. […] A logjam of nearly 800 new chemicals has developed in the EPA's new chemicals office since the Toxic Substances Control Act was amended June 22, 2016. The agency has authorized only 63 new chemicals and microbes as ... read more >
May 4, 2017
Lynn L. Bergeson and Richard E. Engler, Ph.D., Contribute to ABA SEER’s The Year in Review 2016
Bergeson & Campbell, P.C. (B&C®) is pleased to announce the publication of The Year in Review 2016:  Environment, Energy, and Resources Law by the American Bar Association (ABA) Section of Environment, Energy, and Resources (SEER).  The Year in Review provides an annual summary of developments in environmental, energy, and resources law.  B&C Managing Partner Lynn L. Bergeson and Senior Chemist Richard E. Engler, Ph.D., co-authored the Pesticides, Chemical Regulation, and Right-to-Know 2016 Annual Report.    The 2016 Annual Report provides a detailed ... read more >
May 2, 2017
ELI, GWU, and B&C Present “TSCA Reform – One Year Later”
  SAVE THE DATE   TSCA Reform – One Year Later June 27, 2017, 9:00 a.m. - 4:30 p.m. (EDT) George Washington University Milken Institute School of Public Health, Washington, D.C. Join the Environmental Law Institute and the George Washington University Milken Institute School of Public Health for a day-long conference exploring the federal government’s implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which significantly amended the Toxic Substances Control Act (TSCA), just over one year after it was signed into law. ... read more >
April 28, 2017
Dr. Richard E. Engler Makes Presentation Regarding TSCA Reform to the Chemical Society of Washington
On April 27, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), presented “Toxic Substances Control Act (TSCA) and TSCA Reform” at the Chemical Society of Washington’s monthly dinner meeting. Dr. Engler discussed TSCA before and after reform by The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) and challenges that the U.S. Environmental Protection Agency (EPA) and industry face in implementing and complying with the new law. In this extensive presentation, Dr. Engler discussed the centralizing concept of ... read more >
April 26, 2017
Bloomberg BNA Daily Environment Report Quotes Richard Engler In “No Insights in EPA Notices on 19 New Chemicals on Market”
On April 25, 2017, Bloomberg BNA Daily Environment Report included comments by Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), commenting on the 19 new chemicals that have been given market approval by the U.S. Environmental Protection Agency (EPA) between December 1, 2016, and February 28, 2017. […] The EPA has notified the manufacturers that asked to make the new chemicals of the approvals and announced the decisions on its public website, Richard Engler, a senior chemist with Bergeson & Campbell, P.C., who spent 17 years working with ... read more >
April 20, 2017
​Inside EPA Article Quotes TSCA Blog Post “EPA Denies TSCA Section 21 Petition on Fluoride Chemicals in Drinking Water; Provides Response to Petition”
On April 19, 2017, Inside EPA quoted a post from the TSCA Blog in the article “Suit Over EPA's Rejection Of Fluoride Ban Claims TSCA Misinterpretation.” “This asserted view, that only a comprehensive risk evaluation considering all conditions of use will suffice, presents a very high threshold for action -- and seemingly an impossibly high threshold to move EPA to act," officials with the law firm Bergeson & Campbell said in a March 7 blog post. […]  Bergeson and Campbell attorneys said that EPA's denial is "essentially arguing that ... read more >
March 29, 2017
Quotes by Charles Auer Included In Bloomberg BNA Daily Environment Report Article “First-Ever Federal Mercury Inventory Set for Release by EPA”
On March 29, 2017, Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Report explaining possible impacts of a mercury inventory under the Toxic Substances Control Act (TSCA). […]The updated chemicals law also calls for the EPA to develop a regulation by June 2018 that will require companies that use mercury or mercury compounds to provide the agency with information about those uses. Pharmaceutical and other companies that normally are not regulated under TSCA may be subject to ... read more >
March 29, 2017
Sheryl Lindros Dolan Presents “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the SCHC Spring Meeting
On March 28, 2017, Sheryl Lindros Dolan, Senior Regulatory Consultant at Bergeson & Campbell, P.C. (B&C®), presented “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the Society for Chemical Hazard Communication (SCHC) Spring Meeting. Ms. Dolan’s presentation reviewed the requirements for confidential business information (CBI) protection under the new Toxic Substances Control Act (TSCA), compared these requirements with those under the Occupational Safety and Health Administration (OSHA) Hazard ... read more >
March 17, 2017
Lynn L. Bergeson and James Aidala Quoted in Inside EPA Article “Fluoride Critics Eye Court Challenge To EPA's Denial Of TSCA Ban Petition”
On March 17, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), and James Aidala, Senior Government Affairs Consultant with B&C, were quoted in an Inside EPA article on the U.S. Environmental Protection Agency’s denial of a Toxic Substances Control Act (TSCA) petition to ban flouride. […]But Lynn Bergeson of the law firm Bergeson & Campbell told Inside EPA in a March 10 email that de novo review "would pose considerable challenges for parties and explains why invoking this relief is rare." Bergeson ... read more >
March 6, 2017
Bloomberg BNA Daily Environment Report Article “New Toxic Controls to Emerge in Chemical Sector's March Madness,” Quotes Lynn L. Bergeson
On March 6, 2017, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), on how B&C will handle the implementation of TSCA Reform. Four law firms contacted by Bloomberg BNA say they are able to file the comments they are preparing without hiring additional staff or contractors. Others say other aspects of TSCA's implementation has prompted them to seek new hires. Lynn Bergeson, managing partner of Bergeson & Campbell PC in Washington, said that the firm may hire additional staff to address the backlog of ... read more >
March 3, 2017
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Proposed EPA Cuts Incense State Funding Proponents”
On March 3, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Report on how proposed EPA budget cuts could impact the chemical and pesticides program. Lynn Bergeson, managing partner of Bergeson & Campbell PC, a Washington, D.C.-based law firm that specializes in chemical and pesticide regulations, told Bloomberg BNA this is good news for the EPA's Office of Chemical Safety and Pollution Prevention Office, which oversees both chemicals and pesticides. The OMB did not recommend any cuts to ... read more >
February 10, 2017
Lynn L. Bergeson Quoted By Bloomberg BNA Daily Environment Report Regarding How Manufacturers Should Participate in EPA Rulemaking
On February 10, 2017, Managing Partner of Bergeson & Campbell, P.C. (B&C®), Lynn L. Bergeson, was quoted in the Bloomberg BNA Daily Environment Report article “Vehicle, Furniture Makers Urged to Increase Role in Toxics Law.” Lynn Bergeson, managing partner of the Washington, D.C., office of Bergeson & Campbell, P.C., said some manufacturers, such as companies that purchase nanoscale chemicals to make sports equipment, aren't well positioned to actively participate in EPA's rulemakings. Nevertheless responsible product manufacturers will want to know ... read more >
February 9, 2017
Inside EPA Article, “Stakeholders Flag Early Concerns On EPA TSCA Risk Evaluation Proposal,” Quotes B&C Memorandum
On February 9, 2017, Inside EPA quoted the Bergeson & Campbell P.C. (B&C®) memorandum, “TSCA: EPA Releases Proposed Chemical Risk Evaluation Process under New TSCA,” regarding how a weight of evidence (WoE) approach would impact U.S. Environmental Protection Agency (EPA) risk evaluations. And a Jan. 19 Bergeson & Campbell memorandum on the proposal says that while the preamble contains language leading toward codifying an effective WoE approach, "A clear statement of EPA's approach to WOE in conducting risk evaluations would provide a discernible ... read more >
January 17, 2017
Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environmental Report Article “Process to Select Chemicals for Risk Review Proposed: EPA”
On January 17, 2017, the Bloomberg BNA Daily Environment Report Article “Process to Select Chemicals for Risk Review Proposed: EPA” included comments by Lynn L. Bergeson, Managing Partner at Bergeson & Campbell P.C. (B&C®), discussing specifics of the U.S. Environmental Protection Agency’s (EPA) proposed risk rule. Lynn Bergeson, managing partner with the Washington D.C.-based law firm Bergeson & Campbell, PC, said she too would have liked EPA's proposed rule to be clearer as to how exactly the criteria would translate into a decision as to whether high ... read more >
January 17, 2017
Bloomberg BNA Daily Environmental Report Article On EPA’s Proposed Commercial Chemical Review Strategy Features Comment By Lynn L. Bergeson
On January 17, 2017, Bloomberg BNA Daily Environment Report included a quote by Lynn L. Bergeson in the article “EPA Proposes Strategy to Identify, Review Commercial Chemicals.” Lynn Bergeson, managing partner of Bergeson & Campbell PC in Washington, D.C., told Bloomberg BNA, “EPA has done the near impossible in proposing three epic rules. Now the burden is on other stakeholders to define, clarify, and help the process along.” http://news.bna.com/deln/display/split_display.adp?fedfid=103349998&vname=dennotallissues&wsn=499469500&scm=DELNWB ... read more >
January 13, 2017
Issues Brought Up During BC-CM Producers Group Meeting Featured By Inside EPA Article
On January 13, 2017, slides from the B&C® Consortia Management’s (BC-CM) NMP Producers Group Meeting with the Office of Management and Budget were discussed in the Inside EPA article “Chemical Makers Cite TSCA Listing In Call For EPA To Drop NMP Proposal.” […] But representatives from Bergeson & Campbell on behalf of NMP producers in a Dec. 5 meeting with EPA and OMB officials ahead of the proposal's release argued that the rulemaking does not appear to be consistent with the completed risk assessment and therefore may violate section 26 under the ... read more >
January 11, 2017
The Top Chemical Regulatory Stories of 2016
  The attorneys, scientists, policy experts, and regulatory advisors of Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) endeavor year-round to keep you informed on key developments as they happen, and prepared for looming changes and deadlines, to help you maintain compliance and competitive advantage as you market your products throughout the world. As the new year begins, we offer you this look back at the top stories of 2016 (as measured by clicks, reads, and shares by readers of our blogs and e-mails), a ... read more >
January 9, 2017
Richard E. Engler, Ph.D. Quoted In Wired Article On New Chemical Regulations
On January 9, 2017, Richard E. Engler, Ph.D., Senior Chemist with Bergeson & Campbell P.C. (B&C®), was quoted in “The Chemical Industry’s Having a Bad Reaction to New Regs.” As a result, some chemists feel like they must dial back their ambitions to pass review. “New chemicals are taking significantly longer to get through the EPA process now,” says Rich Engler, a chemical consultant with environmental law firm Bergeson & Campbell. “If I were advising a client I would tell them to only try to develop something low hazard, because those are ... read more >
January 5, 2017
Bloomberg BNA Daily Environment Report Article Quotes Charles M. Auer On Chemical Data Reporting Rule
On January 5, 2017, the Bloomberg BNA Daily Environment Report Article, “Outlook 2017: Amended Chemicals Law Implementation Top Priority,” quoted Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), regarding how Chemical Data Reporting (CDR) Rule information will be used in the future to help prioritize risk evaluations and other chemical regulatory activities. The EPA's Office of Chemical Safety and Pollution Prevention has work to do in 2017 beyond the specific mandates of the amended TSCA law. For example, the Chemical ... read more >
December 28, 2016
Biobased Chemical, Fuel Makers Seek Parity For Their Products Under Trump
Lynn L. Bergeson was quoted in the December 28, 2016, Bloomberg BNA Daily Environment Report story "Biobased Chemical, Fuel Makers Seek Parity For Their Products Under Trump" (subscription required): Biobased chemical and fuel manufacturers want their products to be treated equally with their fossil fuel-based counterparts under the incoming administration's policies. [...]  Lynn Bergeson, managing partner of the Washington D.C.-based Bergeson & Campbell, P.C., which manages the Biobased and Renewable Products Advocacy Group (BRAG), said Pruitt’s alignment with ... read more >
December 7, 2016
Oscar Hernandez and Jim Aidala Quoted in “Risk Limits Under New Toxics Law May Continue Past Practice”
On December 7, 2016, the Bloomberg BNA Daily Environment Report quoted Oscar Hernandez, Ph.D., Senior Regulatory Chemist with Bergeson & Campbell, P.C. (B&C®), and Jim Aidala, Senior Government Affairs Consultant with B&C, regarding how the U.S. Environmental Protection Agency (EPA) will handle the new toxics law. Typically, the agency takes action on chemicals whose risks range between 1 in 10,000 excess cancer cases to 1 in 1 million excess cases. “They'd have to explain why they're moving out of that range if they did anything different,” former EPA ... read more >
November 30, 2016
Lynn L. Bergeson and Charles M. Auer Discuss Changes to EPA’s New Chemicals Program
On November 30, 2016, the Bloomberg BNA Daily Environmental Report included comments by Charles M. Auer, Senior Regulatory and Policy Advisor with Bergeson & Campbell, P.C. (B&C®), and Lynn L. Bergeson, Managing Partner of B&C, in the article “Groans Heard About Pace EPA's New Chemical Reviews.” The EPA appears to be making changes to the new chemicals program beyond what the law mandated, Charles Auer, former director of the EPA's Office of Pollution Prevention and Toxics, told Bloomberg BNA Nov. 21. He described the Lautenberg Act's revisions to ... read more >
November 14, 2016
James V. Aidala Comments in BNA Daily Environment Report Regarding Trump Transition at EPA
The November 14, 2016 BNA Daily Environment Report featured comments from James V. Aidala, Senior Government Affairs Consultant for Bergeson & Campbell, P.C., in the story “Trump Transition Team Expected Soon at EPA To Begin Review of Agency Actions, Priorities”: Trump’s EPA transition team will likely receive ‘‘massive briefing books’’ on each of the agency’s programs, including air pollution, water, waste and pesticides, according to Jim Aidala, a senior government affairs consultant with Bergeson & Campbell P.C. in Washington D.C. ... read more >
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 >
August 4, 2016
B&C Memorandum Quoted In Inside EPA Article “Attorneys Say EPA SNUR Aligning Protection With OSHA May Exceed TSCA”
On August 4, 2016, quotes from the Bergeson & Campbell P.C. (B&C®) memorandum “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards” were included in an Inside EPA article about conflicts between Occupational Safety and Health Administration (OSHA) and the revised Toxic Substances Control Act (TSCA). A law firm that frequently represents industry clients is warning that a recently proposed rule that seeks to align EPA requirements for new uses of industrial chemicals with strict Occupational Safety ... 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 >
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