Endocrine Disruptors

Lynn L. Bergeson, "EPA Goes Back To The Drawing Board On Toxic Substances," Chemical Processing, September 15, 2021.

The implementation of the Toxic Substances Control Act (TSCA) provisions relating to regulating persistent, bioaccumulative and toxic (PBT) chemicals has been anything but smooth. On September 3, 2021, the Environmental Protection Agency (EPA) announced it intends to initiate new PBT rulemaking and anticipates proposing new rules for five PBT chemicals subject to final risk management rules under TSCA Section 6(h). Additionally, and happily, the agency extended the compliance dates for the prohibitions on processing and distribution and the associated recordkeeping requirements of one of these PBT chemicals, phenol, isopropylated phosphate (3:1) (PIP (3:1)). The action was imperative as EPA’s earlier-issued “No Action Assurance” (NAA) lapsed on September 4, 2021. This article provides key points related to this complicated area of TSCA regulation.

Lynn L. Bergeson, "Enlisting Modern Technologies to Ensure a Safe Food Supply," Natural Resources & Environment, Volume 31, Issue 3, Winter 2017.

Nanotechnology, biotechnology, and synthetic biology are the ploughs and tractors of the twenty-first century. These precision farming tools are ensuring a sustainable food supply otherwise threatened by climate change and population growth, among other global challenges. Genetically modified E. coli is being used to produce synthetically derived pheromones, substances beneficially used in agricultural applications to attract, capture, and eliminate harmful pests. Nanopesticides and nanofertilizers are being effectively used in drought-stricken regions, eliminating or minimizing the need for conventional agricultural chemicals. These and similar technologies are essential to enable today’s agricultural professionals to compete with an increasingly unforgiving Mother Nature and an ever-increasing demand for food.


These emerging technologies do not come without potential risks, however. How to regulate them is a  subject upon which stakeholders disagree.


Against this backdrop, this article considers emerging agricultural technologies, and discusses domestic agricultural oversight systems and their ability to keep pace with innovation. As discussed below, the domestic governance system is capable of addressing comprehensively the potential risks posed by these evolving technologies. The system, however, could be improved by better integration of measures  to educate policy makers and regulators on these technologies, and greater involvement by the private  sector in facilitating a predictable flow of information on these technologies to all stakeholders.

Lynn L. Bergeson, "EPA Continues Chemical Screening Tests," Chemical Processing, August 20, 2015.

The release of the first Tier 1 assessments in the Endocrine Disruptor Screening Program (EDSP) by the U.S. Environmental Protection Agency (EPA) on June 30, 2015, is a significant benchmark in the program since the original List 1 test orders were issued in October 2009. This column explains why.

Lynn L. Bergeson, "EPA Releases List of EDSP Universe of Chemicals," Pollution Engineering, February 1, 2013.

On November 27, 2012, EPA released The EDSP Universe of Chemicals and General Validation Principles, as well as the list of approximately 10,000 chemicals. This article explains the document and its implications.

Lynn L. Bergeson, "EPA Releases EDSP Management Plan," Chemical Processing, July 2012.

The U.S. Environmental Protection Agency (EPA) released on June 28, 2012, an Endocrine Disruptor Screening Program (EDSP) "Comprehensive Management Plan." While it's intended for internal use, EPA made the plan available to the public to be consistent with its stated objectives for transparency. The plan and its implications are discussed.

Lynn L. Bergeson, "EPA Issues Final Weight-of-Evidence Guidance," Chemical Processing, October 2011.

On September 28, 2011, the U.S. Environmental Protection Agency (EPA) published its final guidance on the weight-of-evidence (WoE) analysis it will use to evaluate the results of data submitted in response to test orders issued for Tier 1 screening under the Endocrine Disruptor Screening Program (EDSP). What follows is a brief overview of the Final WoE Guidance, which is available at http://www.regulations.gov.

Lynn L. Bergeson, "Washington: Safe for Humans?," Manufacturing Today, Summer 2010.

Hundreds of U.S. businesses have already received in the mail test orders issued by the U.S. Environmental Protection Agency (EPA) for initial endocrine screening under the Endocrine Disruptor Screening Program (EDSP). Hundreds more will receive orders later this year. How recipients respond to an EDSP test order can present challenging issues. This article explains why.

Lynn L. Bergeson, "Legal Lookout: Endocrine Disruptors: Test Orders Abound," Pollution Engineering, June 2010.

In April 2009, EPA identified a final list of 67 chemicals for initial screening under the Endocrine Disruptor Screening Program (EDSP). From October 2009 to April 2010, the agency issued more than 700 test orders. Responding to an EDSP test order can present challenging issues. The agency began implementing this mandate well over a decade ago through the EDSP.

Lynn L. Bergeson, "The Endocrine Disruptor Screening Program: Where Are We?," Environmental Quarterly Management, Autumn 2009.

On April 15, 2009, the U.S. Environmental Protection Agency (EPA) issued its final list of chemicals in the first group of substances that will be screened under the Endocrine Disruptor Screening Program (EDSP). Development of this list caps a long, thoughtful, and arduous administrative process that spans over a decade. This “Washington Watch” column briefly reviews the development of the program, with emphasis on key elements of the current EDSP. The discussion also highlights the implications of the program for industry stakeholders.

Lynn L. Bergeson, Lisa M. Campbell, and Lisa R. Burchi, "Endocrine Disruptor Screening Program: Data Sharing, Compensation, Protection," BNA Daily Environment Report, June 29, 2009.

The U.S. Environmental Protection Agency (EPA) issued three important Federal Register notices April 15, 2009, laying the foundation for the Endocrine Disruptor Screening Program (EDSP), EPA’s next major data development initiative. This article focuses on those aspects of EPA’sFederal Register notices concerning how EPA will address joint data development, cost sharing, data compensation, and data protection under the EDSP (EDSP Policy Notice)

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