January 18, 2017

EPA Proposes Procedures to Prioritize Chemicals for Risk Evaluation under TSCA

The U.S. Environmental Protection Agency (EPA) proposed on January 17, 2017, procedures to establish the risk-based screening process and criteria that EPA will use to identify chemical substances under the Toxic Substances Control Act (TSCA) as either High-Priority Substances for risk evaluation, or Low-Priority Substances for which risk evaluations are not warranted at the time. 82 Fed. Reg. 4825. The proposed rule describes the processes for identifying potential candidates for...
January 17, 2017

Bloomberg BNA Daily Environmental Report Article On EPA’s Proposed Commercial Chemical Review Strategy Features Comment By Lynn L. Bergeson

On January 17, 2017, Bloomberg BNA Daily Environment Report included a quote by Lynn L. Bergeson, President of The Acta Group (Acta®), in the article “EPA Proposes Strategy to Identify, Review Commercial Chemicals.” Lynn Bergeson, managing partner of Bergeson & Campbell PC in Washington, D.C., told Bloomberg BNA, “EPA has done the near impossible in proposing three epic rules. Now the burden is on other stakeholders to define, clarify, and help the process...
January 17, 2017

Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environmental Report Article “Process to Select Chemicals for Risk Review Proposed: EPA”

On January 17, 2017, the Bloomberg BNA Daily Environment Report Article “Process to Select Chemicals for Risk Review Proposed: EPA” included comments by Lynn L. Bergeson, President of The Acta Group (Acta®), discussing specifics of the U.S. Environmental Protection Agency’s (EPA) proposed risk rule. Lynn Bergeson, managing partner with the Washington D.C.-based law firm Bergeson & Campbell, PC, said she too would have liked EPA’s proposed rule to be clearer as to...
January 17, 2017

TSCA: EPA Proposes Requirements for TSCA Inventory Notification (Active-Inactive)

On January 13, 2017, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would require an electronic notification for chemical substances listed on the Toxic Substances Control Act (TSCA) Inventory that were manufactured (including imported) for non-exempt commercial purposes during the ten-year time period ending on June 21, 2016. 82 Fed. Reg. 4255. EPA would also accept such notices for chemical substances that were processed. The recent TSCA amendments require EPA to...
January 17, 2017

TSCA: EPA Proposes Regulation of TCE Use in Vapor Degreasing under TSCA Section 6(a)

In an expected action, on January 11, 2017, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a proposed rule under Section 6(a) of the Toxic Substances Control Act (TSCA) to regulate the use of trichloroethylene (TCE) in vapor degreasing.  The proposed rule has not yet been published in the Federal Register, but a pre-publication version of the proposed rule is available on EPA’s website, along with a fact sheet and other information.  The...
January 16, 2017

WEBINAR – – Chemical Substance Regulation in Central and South America: A Deeper Dive

REGISTER TODAY Thursday, February 16, 2017, 2:00 p.m. Eastern Standard Time The Central and South American chemical regulatory environment continues to be one that is challenging to understand, navigate, and manage from a business perspective.  These challenges most often stem from one of three aspects:  a lack of knowledge concerning the regulatory and governmental authority structure; a challenge in determining which regulations (local, national, and/or trade bloc) apply;...
January 13, 2017

Issues Brought Up During BC-CM Producers Group Meeting Featured By Inside EPA Article

On January 13, 2017, slides from the B&C® Consortia Management’s (BC-CM) NMP Producers Group Meeting with the Office of Management and Budget were discussed in the Inside EPA article “Chemical Makers Cite TSCA Listing In Call For EPA To Drop NMP Proposal.” […] But representatives from Bergeson & Campbell on behalf of NMP producers in a Dec. 5 meeting with EPA and OMB officials ahead of the proposal’s release argued that the rulemaking does not...
January 13, 2017

EPA Final Rule Raises The Limits For Civil Penalties

In a final rule issued on January 12, 2017, EPA adjusted the level of statutory civil monetary penalty amounts under the statutes EPA administers. 82 Fed. Reg. 3633. The adjustments are mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended through the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The latter law prescribes a formula for annually adjusting statutory civil penalties to reflect inflation, maintain the deterrent effect...
January 12, 2017

EPA Promulgates Final TSCA Reporting and Recordkeeping Rule for Nanoscale Materials

After over a decade of effort, the U.S. Environmental Protection Agency (EPA) issued on January 12, 2017, a final rule under Section 8(a) of the Toxic Substances Control Act (TSCA) establishing reporting and recordkeeping requirements for certain discrete forms of chemical substances that are manufactured or processed at the nanoscale. 82 Fed. Reg. 3641. Manufacturers and processers, or persons who intend to manufacture or process new discrete forms of certain existing chemical nanoscale...
January 11, 2017

The Top Chemical Regulatory Stories of 2016

The attorneys, scientists, policy experts, and regulatory advisors of Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) endeavor year-round to keep you informed on key developments as they happen, and prepared for looming changes and deadlines, to help you maintain compliance and competitive advantage as you market your products throughout the world. As the new year begins, we offer you this look back at the top stories of...