BA, Cornell University, Chemistry, 1988

JD, The National Law Center, George Washington University, 1991  

Sheryl Dolan is an excellent asset to clients who have issues in chemical regulation, registration, and compliance management matters. She works with manufacturers of conventional and nanoscale chemicals, and industrial and consumer products, including intergeneric microorganisms, for compliance with requirements under the Toxic Substances Control Act (TSCA). She also works with registrants of agricultural and other conventional pesticides, antimicrobial products, biopesticides, and plant regulators to register and manage compliance with requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Ms. Dolan helps reduce enforcement risk and improves product stewardship practices for Bergeson & Campbell, P.C. (B&C^®) clients by assisting them in assessing and improving compliance practices. She also can assist in bringing new and/or improved products to market by obtaining timely regulatory approvals of new chemicals and products. She has worked with several clients to leverage environmentally preferable and bio-based product attributes into sales opportunities.

Ms. Dolan regularly assists clients in addressing compliance questions under federal and state law. She is an expert in development and assessment of compliance management systems. She conducts compliance audits as part of corporate third-party audit policies as well as pursuant to enforcement consent agreements. She also conducts due diligence audits according to three-way non-disclosure agreements between acquiring companies and target acquisitions.

For pesticide manufacturers, Ms. Dolan:

• Represents clients in interactions with the Office of Pesticide Programs (OPP), engaging regulatory and science staff in pre-registration meetings and in response to issues arising during application review.
• Plans and coordinates preparation of FIFRA registration and amendment applications, tolerance and exemption petitions, notifications, and other submissions, including establishment registrations and annual reports, fee filings, supplemental distributor notices, and Section 6(a)(2) reports.
• Prepares and updates product labels.
• Assists with data compensation analyses.
• Works with clients and OPP staff to meet conditions of registration.
• Assists clients with pesticide reregistration and registration review processes.

For chemical manufacturers, Ms. Dolan:

• Represents clients in interactions with the Office of Pollution Prevention and Toxics, in pre-submission meetings and in response to issues arising during submission review.
• Coordinates development of TSCA pre-manufacture notices, microbial commercial activities notifications, exemption applications, and polymer exemption analyses.
• Assists clients in meeting their Chemical Data Reporting (formerly Inventory Update Reporting) rule requirements and navigating the U.S. Environmental Protection Agency’s (EPA) recent and increasingly complex reporting obligations.
• Assists clients with TSCA Section 8(e) analyses and submissions.

Before joining B&C in 2003, Ms. Dolan was with The Shaw Group and Stone & Webster-JSC Management Consultants, Inc. (formerly Jellinek, Schwartz & Connolly, Inc.).

Representative Engagements:

• Managed and coordinated efforts on behalf of a small start-up company to register and obtain a tolerance exemption for a new microbial pesticide to meet an important -- and otherwise unaddressed -- public health issue.
• Developed arguments to persuade EPA of its error in making “technical” corrections to an existing tolerance that effectively eliminated a tolerance for an existing crop use.
• Assisted a large, multi-national company in researching and developing regulatory and science-based arguments to support EPA’s conclusion that the client’s recently developed technology is eligible for a FIFRA regulatory exclusion.
• Assisted a large chemical product manufacturer with assessing the value of its pesticide product registration in anticipation of business divestiture.
• Assisted a cleaning product manufacturer in meeting the requirements applicable to a pesticidal device and developed strategies for product testing in support of public health claims.
• Worked with a commercial products manufacturer in coordinating lab testing to identify heretofore-unknown chemical moieties in several products and assess for exemption eligibility from TSCA inventory requirements.
• Guided a pesticide registrant through reviewing the existing EPA database in support of a technical product, developing strategies for data waiver requests, and preparing responses to generic and product-specific data call-ins.
• Worked with a chemical manufacturer to develop Low Release and Exposure (LOREX) exemption applications for new nanoscale pigments.
• Participated in the preparation and coordination of training webinars for regulatory staff in a company’s 15-20 subsidiaries on product regulation, risk assessment, and hazard communication issues.

Bar & Court Admissions:

New York State Bar, 1992

District of Columbia Bar, 1993

Publications:

Books:

Lynn L. Bergeson, Charles M. Auer, Co-Editors; Timothy D. Backstrom, Lisa R. Burchi, Lisa M. Campbell, Sheryl L. Dolan, Richard E. Engler, Ph.D., Margaret R. Graham, Oscar Hernandez, Ph.D., Carla N. Hutton, Kathleen M. Roberts, Contributing Authors, New TSCA: A Guide to the Lautenberg Chemical Safety Act and Its Implementation, American Bar Association Section of Environment, Energy, and Resources (2017).

Lynn L. Bergeson, Editor; Bethami Auerbach, Lynn L. Bergeson, Lisa R. Burchi, Lisa M. Campbell, Sheryl L. Dolan, Ruth C. Downes-Norriss, Carla N. Hutton, Leslie S. MacDougall, Henry M. Jacoby, Kathleen M. Roberts, Contributing Authors, Global Chemical Control Handbook: A Guide to Chemical Management Programs, American Bar Association Section of Environment, Energy, and Resources (2014).

Articles:

L. Bergeson, B. Auerbach, L. Campbell, T. Backstrom, S. Dolan, J. Vergnes, R. Engler, J. Bultena, K. Baron, C. Auer, "The DNA of the U.S. Regulatory System: Are We Getting It Right for Synthetic Biology?," Woodrow Wilson International Center for Scholars Synthetic Biology Project Report, October 15, 2015.

Speaking Engagements:

“2018 FIFRA Regulatory Outlook,” CPDA 2018 Regulatory Policy Conference, Crystal City, Virginia (March 13, 2018).

"Protecting Trade Secrets Around the World: Comparing CBI Requirements of the TSCA Reform Act to ASHA HCS 2012, Appendix E," The Society for Chemical Hazard Communication Spring 2017 meeting, New Orleans, Louisiana (March 28, 2017).

“WEBINAR - The New TSCA Webinar 4: Preemption, PBTs, Fees, and Judicial Review,” Chemical Watch (October 4, 2016).

"Leveraging Synthetic Biology's Promise and Managing Potential Risk," Woodrow Wilson International Center for Scholars Synthetic Biology Project Seminar and Webinar, Washington, D.C. (October 15, 2015).

"EPA's Supplemental Distribution Enforcement Actions Are Buzzing: How to Avoid Getting Stung," Bergeson & Campbell P.C. Webinar (July 23, 2014).