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August 12, 2020

Richard E. Engler, Ph.D., Quoted in Bloomberg Environment Article “Utilities Want to Use EPA Chemicals Law to Protect Drinking Water”

Bergeson & Campbell, P.C.

On August 10, 2020, Bloomberg Environment featured comments by Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®) regarding water utilities requesting the U.S. Environmental Protection Agency (EPA) use all its regulatory tools to safeguard drinking water as it decides whether to allow new chemicals into U.S. commerce.

The utilities’ efforts are part of a broader trend in which new businesses are recognizing the chemicals law can affect them, said Richard E. Engler, director of chemistry at the law firm Bergeson and Campbell PC.

“More and more people are realizing that they are TSCA stakeholders, and they need to be aware and engaged with the law on both existing and new chemicals,” said Engler, whose firm advises the TSCA New Chemicals Coalition, a group of chemical manufacturers that share experiences or concerns about the agency’s new chemicals program.

But voicing general concerns may not achieve specific goals, said Engler, who worked in the agency’s chemicals office for 17 years before joining Bergeson and Campbell.

The EPA already looks at a substance’s potential to expose people or aquatic life using very conservative, or protective, assumptions as it reviews a company’s request to make a new chemical, he said. For example, the agency often assumes wastewater treatment wouldn’t remove any amount of a chemical, he said.


Comments that are specific to the new chemical the EPA is examining and that identify errors, missing information, or other problems in that a specific case are most likely to elicit changes in its the proposed rule, Engler said.

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