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Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are very pleased to announce that Charles M. Auer has joined our teams as Senior Regulatory and Policy Advisor. For more than three decades, Mr. Auer has provided sagacious, informed, and deeply insightful guidance on legal, policy, and scientific matters related to the regulation of chemicals under the Toxic Substances Control Act (TSCA) and related domestic and international chemical control laws. Mr. Auer’s experience...

The Ministry of the Environment (MOE) published an amended version of the Act for the Registration and Evaluation of Chemicals (K-REACH) enforcement decree and enforcement rules, which have both entered into force. The amendments include some exemptions from reporting for new chemicals, and an extended 14-day grace period for substances used only for research and development (R&D) purposes. The final amendments do not include a proposal to remove a provision that states...

On August 25, 2016, Acta affiliate Bergeson & Campbell, P.C.’s (B&C®) memoranda “TSCA Reform: Proposed Changes to SNUR Procedures Would, Perhaps Inadvertently, Result in Disclosure of CBI to Third Parties/Possible Competitors” and “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” were discussed in an Inside EPA article on how Toxic Substances Control Act (TSCA) Reform may violate trade secret...

China Implements Requirements For Shipments From Zika-Infected Countries, Including The U.S.: In March 2016, the General Administration of Quality Supervision, Inspection, and Quarantine (AQSIQ) began requiring all countries on its Zika-infected list to comply with disinsection requirements. The United States Department of Agriculture (USDA) Foreign Agricultural Service’s (FAS) August 19, 2016, “Update on China’s Requirements for Shipments from Zika-Infected...

On August 18, 2016, Chemical Watch quoted Acta affiliate Bergeson & Campbell, P.C.’s (B&C®) memorandum, “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” in an article examining the conflict between the U.S. Environmental Protection Agency’s (EPA) Significant New Use Rule (SNUR) proposal and the revised Occupational Safety and Health Administration’s (OSHA) Hazard Communications Standard...

On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, President of The Acta Group (ACTA®), in the article, “Give EPA Detailed New Chemical Notices, Attorneys Advise.” Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much more strategic, thoughtful...

On August 11, 2016, the Bloomberg BNA Daily Environment Report quoted Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C. (B&C®) And Acta, on the implication of additional fees created by Toxic Substance Control Act (TSCA) reform. Companies that pay the costs of generating toxicity, exposure and other data should not be “double billed” through additional fees to review the resulting...

On July 28, 2016, the U.S. Environmental Protection Agency (EPA) proposed to update the Toxic Substances Control Act (TSCA) Significant New Use Rule (SNUR) procedures. 81 Fed. Reg. 49598. As discussed in our previous memorandum on this proposed rule, Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards, while some of the proposed changes are not consequential, other changes, such as those related to workplace protections, are more clearly...

On August 4, 2016, quotes from Acta affiliate Bergeson & Campbell P.C.’s (B&C®) memorandum “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards” were included in an Inside EPA article about conflicts between Occupational Safety and Health Administration (OSHA) and the revised Toxic Substances Control Act (TSCA). A law firm that frequently represents industry clients is warning that a recently proposed...

SWA Announces New Chemical Database: On July 5, 2016, Safe Work Australia (SWA) announced the Hazardous Chemical Information System (HCIS), a new database that provides information on chemicals that have been classified in accordance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The database features classification and labeling information for over 4,500 chemicals, including pictograms, and a searchable database of workplace exposure standards....