July 24, 2025

Lynn L. Bergeson, “Leveraging Chemical Data More Efficiently,” PCB007 Magazine, July 2025.

Some truths transcend politics, one being that chemical data holds enduring value and is becoming increasingly essential. In the United States, regardless of which party federally controls the levers of power, it's clear that chemical manufacturers and their customers must develop and curate robust data portfolios for their chemical inventories. The commercial imperatives driving this are undeniable and gaining traction.
July 14, 2025

Lynn L. Bergeson, “Good News: PFAS Reporting Deadline Postponed,” Chemical Processing, July 14, 2025.

The Minnesota Pollution Control Agency (MPCA) announced recently that it will postpone the Jan. 1, 2026, reporting deadline on products containing intentionally added per- and polyfluoroalkyl substances (PFAS). This is welcome news for businesses that were frantically preparing for the fast-approaching deadline. This column explains the state’s PFAS reporting rule, and summarizes the current, fluid state of play in this state’s evolving PFAS program.
June 17, 2025

Lynn L. Bergeson, “Chemical Policy Crossroads: What Are the Make America Healthy Again Report’s Implications?,” Chemical Processing, June 17, 2025.

In partial response to President Trump’s Feb. 13, 2025, Executive Order (EO) 14212, “Establishing The President’s Make America Healthy Again Commission,” the White House issued on May 22, 2025, “The MAHA Report” (with MAHA an acronym for Make America Healthy Again), titled “Make Our Children Healthy Again: Assessment.” If you have not read it, you should, as it raises, but does not answer, interesting questions for manufacturers of all stripes, especially those whose products...
May 14, 2025

Lynn L. Bergeson, “EPA Outlines Actions to Address PFAS,” Chemical Processing, May 14, 2025.

On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s much anticipated announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” 
April 16, 2025

Lynn L. Bergeson, “Rethinking Environmental Governance: The Age of Deregulation?,” Chemical Processing, April 16, 2025.

Candidate Trump promised to roll back regulations when he ran for president last campaign cycle. He has claimed deregulation was a hallmark of his first term and that his second term would be even more “deregulatory.” Experts will disagree on whether any one president succeeds in reducing the federal regulatory burden. What we do know is that Trump 2.0 has taken early and aggressive deregulatory measures expected to significantly impact many sectors of the U.S. economy. 
March 14, 2025

Lynn L. Bergeson, “EPA, OSHA Sign Ambiguous Memorandum of Understanding,” Chemical Processing, March 12, 2025.

The U.S. Environmental Protection Agency announced on Jan. 13, 2025, that it signed a much-anticipated memorandum of understanding (MOU) with the Occupational Safety and Health Administration (OSHA), formalizing coordination on EPA’s work to assess and manage existing chemicals under Section 6 of the Toxic Substances Control Act (TSCA). A closer read of the MOU leaves us wanting more than what is there.
February 18, 2025

Lynn L. Bergeson, “Chemical Compliance: Is TSCA Reform in Our Future?,” Chemical Processing, February 18, 2025.

It’s been almost nine years since Toxic Substances Control Act (TSCA) stakeholders celebrated President Obama’s enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) on June 22, 2016. Because the road to amending TSCA was long (almost a decade), contentious and complicated, stakeholders may have been more relieved that the process was finally over than interested in the fine print.
February 7, 2025

Lynn L. Bergeson, Kelly N. Garson, and Lara A. Hall, “Testing, Testing,” Environmental Forum, March/April 2025.

A key force propelling reform of the Toxic Substances Control Act through Congress in 2016 was a bipartisan belief, shared by the business and environmental communities alike, that the Environmental Protection Agency needs more information to do its job of protecting the American public from adverse effects caused by chemical exposures. After all, it has been domestic policy under TSCA for almost a half century that “adequate information should be developed . . . and that the development of...
January 29, 2025

Lynn L. Bergeson, “The “Undoing” Season,” American College of Environmental Lawyers (ACOEL) Blog, January 29, 2025.

It has been almost nine years since Toxic Substances Control Act (TSCA) stakeholders celebrated President Obama’s enactment on June 22, 2016, of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). Because the road to amending TSCA was long (almost a decade), contentious, and complicated, stakeholders were perhaps more relieved that the process was finally over than inclined to focus on the fine print. This article discusses mid-course corrections that are desperately...