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Global Chemical Notification Programs

Overview:

Registering new chemical products or expanding product registrations for existing chemical products to new markets involves strategic considerations and detailed administrative  tasks. Regulations affecting chemical product approvals vary significantly from market to market. U.S. chemical regulation under the Toxic Substances Control Act (TSCA), the European Union (EU) regulation under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) legislation, and Chinese regulation under the Provisions on Environmental Administration of New Chemical Substances are three prominent and distinct examples of major regulatory schemes companies in the chemical space must navigate. Failure to do so efficiently can be costly.

Developing the right approach from market to market requires sound knowledge of its authorities and how to work within their regulatory programs. The Acta Group (Acta®), with offices in the U.S., Europe, and China, manages chemical products from concept to approval, utilizing the skills and experience of professionals who have worked in the specific product areas in government and industry.

Our Experience:

Acta professionals have experience in regulations affecting chemical product approvals under North American (U.S., Canada, and Mexico), EU, South American, Asian, and Pacific Rim regulatory programs. We regularly track significant legislative, administrative, and scientific initiatives that relate to the business of clients marketing chemicals and medical products for multiple uses.

James Aidala is a former U.S. Environmental Protection Agency (EPA) Assistant Administrator for Toxics under the Clinton Administration. Mr. Aidala has been closely involved with TSCA legislative reauthorization and key regulatory matters for over two decades, and offers significant value in addressing chemical policy and related issues.

Andrew Bourne has significant experience in regulatory and chemical management matters. He offers regulatory advice on issues involving the EU’s REACH legislation and regulatory matters around the globe. His services include strategic advice on the classification and labeling of substances and mixtures, testing strategy advice, and compilation of regulatory documents. Mr. Bourne has produced Chemical Safety Reports (CSR) for Annex IX and X registrations and assisted in biocides and plant protection registrations. 

Andrew Burgess brings to Acta his extensive knowledge of international chemical control legislation and regulatory affairs. While Mr. Burgess’ experience extends from China to Europe, he currently concentrates on matters through Acta’s practice in China. He advises clients on chemical registrations, preparation of dossiers and chemical safety assessments (CSA), as well as post-submission matters. Mr. Burgess has been deeply engaged in China chemical registration and support activities for the last six years and has gained unique insights and knowledge of the legislation and its practical implications for businesses.

Non-lawyer professionals Sheryl Dolan and Barbara Christianson provide invaluable TSCA chemical notification and submission support services.

Regulatory specialist Ruth Downes-Norriss provides expert counsel on EU regulatory matters, in particular on activities falling under REACH. Ms. Downes-Norriss has been involved in REACH registrations and notifications since shortly after the program took effect.  Her involvement from early on in the program’s history has won her important contacts with authorities, including the European Chemicals Agency (ECHA) and national helpdesks.

Leslie MacDougall, Director of Regulatory Affairs, brings extensive experience in global regulatory chemical control programs, including ten years at EPA. Among many other roles, Ms. MacDougall served as the U.S. representative on technical REACH-related issues, and as a liaison among EPA, the Organization for Economic Cooperation and Development (OECD), and OECD country governments. Ms. MacDougall provides expert assistance to clients regarding compliance matters and assistance in preparing and submitting registrations for new and existing chemicals in the more than 40 countries in which Acta operates. A recognized leader in international chemical control legislation, Ms. McDougall speaks often at global conferences and has been published in Chemical Regulation Reporter and Daily Environment Report.

Regulatory Specialist Gyöngyi (Pearl) Németh, M.Sc., a tri-lingual (English, German, Hungarian) with a Masters degree in Environmental Engineering and a post-graduate degree in Experimental Toxicology, delivers considerable international experience solving complex regulatory registration, commercialization, and compliance issues.

Drs. David Peveler and Joseph Plamondon, both with doctorates in organic chemistry, have spent decades consulting with chemical companies on a broad range of TSCA issues, assist with substance identification issues in association with REACH, and have written extensively on chemical regulatory matters.

Dr. Jane Vergnes, who holds a doctorate in human genetics, spent 25 years in global product stewardship at major international chemical companies, and is expert at guiding clients through the international web of chemical regulations cost effectively.

Dr. Susan Youngren, who has a Ph.D. in environmental biology, has more than 30 years of experience in the field of risk assessment and is well-suited to assist clients before EPA when exposure issues are raised in the context of premanufacture notification (PMN) reviews.

Lara Hall, M.S., a scientist and Registered Quality Assurance Professional for Good Laboratory Practice (RQAP GLP), offers clients a tremendous depth of experience with data development, fate and effects modeling, environmental risk assessment, and application/notification preparation to support new and existing registrations worldwide, including those required by FIFRA and TSCA in the U.S., REACH and BPR in the EU, and PMRA in Canada.

What We Do:

Acta professionals are highly experienced in regulatory issues following from compliance with TSCA, REACH, China REACH, and other regulatory programs. We assist clients on a wide range of areas, including product approval, product review, and general compliance measures. Areas in which we advise clients include the following:

  • New Substance Notification Services –
    • Analyze notification schemes and develop notification strategies on a product-specific and market-specific basis.
    • Design and coordinate testing programs to comply with notification requirements across markets, including developing non-testing methods such as Quantitative Structure Activity Relationship (QSAR) and Read Across where possible
    • Prepare notification dossiers
    • Assist with reporting obligations for new and existing chemicals
  • General Compliance Reviews –
    • Assess whether client facilities are sufficiently staffed and equipped; prepare compliance manuals and standard operating procedures (SOP); conduct in-house training seminars
  • Specific Regulatory Reviews –
    • Assist clients with adherence to:
      • PMN/Microbial Commercial Activity Notice (MCAN) requirements
      • Voluntary Children’s Chemical Evaluation Program (VCCEP) requirements
      • PMN requirements pertinent to products of nanotechnology and engineered nanoscale materials
      • Section 5 Significant New Use Rules (SNUR)
      • Section 6 chemical restrictions, including bans
  • Recordkeeping and Reporting Assistance –
    • Assist clients with their recordkeeping and reporting requirements, SOPs, and systems development issues
    • Update notification dossiers and fulfill other post-notification obligations as required in markets where a product has been certified

Representative Engagements:

  • Acta routinely collects, prepares, and performs new chemical substance notifications (NCSN) for a variety of countries.
  • Acta regularly counsels prominent multinational chemical manufacturers on the legal, regulatory, policy, and business implications of evolving TSCA, REACH, China  NCSN, and other rulemaking initiatives to ensure product stewardship alignment.
  • Acta has negotiated dozens of Enforcement Consent Agreements (ECA) under TSCA Section 4, resulting in diminished testing requirements.
  • Acta, along with its affiliates Bergeson & Campbell, P.C. (B&C®) and B&C® Consortia Management, L.L.C. (BCCM), routinely counsels TSCA testing consortia on TSCA Sections 4 and 5 testing obligations and on voluntary product stewardship testing initiatives.
  • Acta routinely counsels on issues pertinent to the management of confidential business information (CBI) under TSCA.
  • Acta counsels clients on harmonizing global chemical product approval and testing programs under TSCA, REACH, China NCSN, and related chemical management programs.

 
THE ACTA GROUP
Beijing, China | Manchester, U.K. | Washington, D.C.
 
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