B&C^® Consortia Management, L.L.C.: Delivering Results through Consortium Management — Part 1

This memorandum is the first in a two-part series providing an overview of the consortia that are managed by B&C^® Consortia Management, L.L.C. (BCCM). Many are aware of Bergeson & Campbell, P.C.’s (B&C^®), The Acta Group’s (Acta^®), and BCCM’s deep expertise and extensive practice on matters related to the Toxic Substances Control Act (TSCA) and support for consortia clients working on issues related to TSCA. Importantly also, BCCM has extensive experience in other chemical regulatory areas, managing consortia that promote product stewardship, conducting chemical testing, and developing industry standards focused on areas unrelated to TSCA. These activities require collaboration of parties with shared interests and expert facilitation to mitigate antitrust risks and deliver results. Here are a few examples of consortia doing just that. We will cover BCCM’s consortia activities related to TSCA in the forthcoming second part of this series.

International Technical Caramel Association

The International Technical Caramel Association’s (ITCA) membership represents caramel color producers across the globe that are focused on promoting the stewardship and safe use of caramel colors. One example of this stewardship is gathering, aggregating, anonymizing, and summarizing industry data to inform assessments of caramel color. BCCM is uniquely positioned to assist in this effort in a way that protects the intellectual property of survey respondents, mitigates antitrust risk, and provides regulators with meaningful data on caramel colors.

ITCA’s Communications Working Group maintains ITCA’s website, www.caramelfacts.org, to provide technical and regulatory resources on caramel color. The Communications Working Group ensures ITCA’s information is current and supported by the latest scientific data for caramel colors. This ensures stakeholders have access to information on caramel colors that is supported by the best available science.

ITCA coordinates with the European Technical Caramel Association (EUTECA) to ensure a globally consistent approach for caramel colors. The two organizations periodically hold joint technical conference calls and meet biannually in person for a day-long technical workshop to discuss science and regulatory activities impacting caramel colors globally.

North American Metals Council

Commodity metal trade associations and the mining industry work together to generate data and ensure the best available science informs risk assessments for metals on a global basis. North American Metals Council (NAMC) members have conducted scientific reviews of the latest research on metals risk assessments. NAMC sponsored the preparation and open access publication of two manuscripts, Recommended updates to the USEPA Framework for Metals Risk Assessment: Aquatic ecosystems and Modeling of local and systemic exposure to metals and metalloids after inhalation exposure: Recommended update to the USEPA metals framework, in peer-reviewed scientific journals to provide industry, regulators, and other stakeholders with the best available science on metals risk assessment. Through proactive collaborations with government agencies, NAMC members have assisted in the development of data and approaches for hazard and risk assessment of metals and metal compounds.

Alu Can Alliance

Established in 2025, the Alu Can Alliance (ACA) is a non-profit organization that serves as the global voice of the aluminum beverage can industry. Global manufacturers of aluminum cansheets and fabricators of aluminum beverage cans formed ACA to advance and promote the sustainability of aluminum beverage cans through the development of industry standards, white papers, and metrics. ACA collaborates with other related organizations and associations to drive scientifically sound and achievable best practices for a more sustainable future.

Currently, ACA is developing a product carbon footprint (PCF) methodology guidance for aluminum cansheets and aluminum beverage cans.

MTBE Consortium

Methyl tert-butyl ether (MTBE) manufacturers and distributors formed the MTBE Consortium to work together to ensure regulatory data needs for MTBE are met and to conduct testing, as needed, to address data gaps.

Metam Task Force

This Task Force of metam pesticide product registrants formed to respond to the U.S. Environmental Protection Agency’s (EPA) data call-in that was issued under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to inform EPA’s review of the metam registration. Members co-sponsored testing and submitted data to satisfy EPA’s data needs, resulting in a successful review and continuation of the metam registration.

Tetrahydrofuran Task Force

Tetrahydrofuran (THF) manufacturers and users develop data and provide technical support through the Tetrahydrofuran Task Force to U.S. state, U.S. federal, and other international government agencies to assess health and environmental impacts and ensure the safe use of THF.

Ethyleneamines Product Stewardship Discussion Group

Formed in 1995 by producers of ethyleneamines, the Ethyleneamines Product Stewardship Discussion Group (EPSDG) provided a forum for producers of ethylenediamine (EDA), diethylenetriamine (DETA), triethylenetetramine (TETA), tetraethylenepentamine (TEPA), polyethylenepolyamines (higher ethyleneamines), aminoethylethanolamine (AEEA), aminoethylpiperazine (AEP), and piperazine (PIP) to discuss and review product stewardship matters related to these products, in the hope of assisting in the safe use and handling of these chemicals by all who come into contact with them. A key accomplishment of this group was the development and publication of a product stewardship manual focused on the safe handling and storage of ethyleneamines to assist entities handling ethyleneamines in establishing safe storage and handling systems. EPSDG sunset in 2021.

Commentary

BCCM provides core support services for industrial, agricultural, and biocide chemical advocacy, testing, and research consortia. BCCM provides a full complement of consortia management services, including consortia formation, full financial services managed by a Certified Public Accountant, organizational support, administration services, and infrastructure/communication platforms. BCCM also provides effective and efficient laboratory communication and management services for consortia that expend significant resources on study data production. BCCM is affiliated with B&C, a Washington, D.C., law firm focusing on conventional, biobased, and nanoscale industrial, agricultural, and specialty chemical product approval and regulation, product defense, and associated business issues, and with Acta, a scientific and regulatory consulting firm with offices in Washington, D.C., Manchester, England, and Brussels, Belgium, providing strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. For further assistance, please e-mail or call bccminfo@bc-cm.com or +1-202-833-6580.