Bloomberg BNA Daily Environment Report Article “Law Firms Help Clients Prep for New Chemicals Law” Quotes Lynn L. Bergeson

On June 10, 2016, Bloomberg BNA Daily Environment Report included comments from Lynn L. Bergeson, President of The Acta Group (Acta^®), speaking about the impacts of passing the Frank R. Lautenberg Chemical Safety for the 21st Century Act.

“The bill’s many deadlines will drive EPA activities at a frantic pace,” said Lynn Bergeson, managing partner of Bergeson & Campbell.

[…] Among the deadlines the EPA faces in the first year of the law’s implementation:

• review final legislative requirements,

• develop a strategic implementation plan,

• identify 10 “TSCA Work Plan” chemicals it will be evaluating within six months of enactment,

• review existing scientific, risk assessment and other science policy guidance and determine where changes or new guidance is needed,

• revise standards for what qualifies as a small business and

• establish a program, rules and schedule for industry fees.

The bill’s mandates for the EPA identify tasks companies should undertake, Bergeson and Duvall said.

To start preparing, they urged companies to:

• read and understand the new law and its implications,

• review the TSCA Work Plan list of chemicals to identify any important to a company’s operations,

• know what chemicals they make, import, use or ship,

• know what health, safety and exposure data they have for those chemicals and

• participate early and often in rulemaking initiatives.

[…] Bergeson said her law firm has cultivated core scientific, administrative, risk assessment and legal competence in chemicals for more than 25 years.

Access to scientific expertise is critical, she said, because, “Disagreements are very common in the area of scientific interpretation.”