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Kelly N. Garson is a Regulatory Consultant with The Acta Group. (Acta^®). Ms. Garson assists clients with Toxic Substances Control Act (TSCA), Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and other federal and state regulatory matters; researches and prepares white papers, briefs, and regulatory memoranda to provide Acta clients with knowledge and strategy to meet regulatory challenges and seize competitive opportunities; and augments the timely and efficient delivery of outstanding client services by the Acta team.

Ms. Garson developed her skills in handling regulatory matters at the local, state, and federal level through an impressive track record of clerkships and internships, including positions with the U.S. Environmental Protection Agency (EPA) Office of Enforcement and Compliance Assurance; the U.S. Department of Justice, Environment and Natural Resources Division; the New York State Department of Environmental Conservation, Region 2 Office; and the New York City Office of Administrative Trials and Hearings.

Ms. Garson holds a JD from The George Washington University Law School, where she served as Editor-in-Chief of the George Washington Journal of Energy and Environmental Law, and degrees in history and environmental studies with a concentration in policy and law from Binghamton University, State University of New York.

Representative Engagements:

• Evaluated TSCA enforcement case policies to assist clients with voluntary e-disclosures and compliance certifications under EPA’s audit policy.
• Assists with submission and evaluation of comments on proposed Significant New Use Rules (SNUR).
• Prepared research and memoranda on the Fees for the Administration of TSCA rule and risk evaluations for high-priority chemicals subject to risk evaluations relating to consortia formation to help companies prepare to engage effectively in advocacy in the risk evaluation.
• Reviewed legislative history and regulatory interpretation of requested risk evaluations under TSCA Section 6(h).
• Prepared guidance on the Polychlorinated Biphenyl (PCB) Cleanup and Disposal Program and regulations regarding cleanup and disposal options for PCB remediation waste.
• Assisted on matters relating to the European Union (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and researched the international pesticide registration protocols, including Middle Eastern countries.
• Assists pesticide companies prepare for FIFRA data compensation negotiations.
• Prepares Freedom of Information Act (FOIA) request letters for submission to various federal agencies and assists in managing responses to the agencies.
• Prepared a non-waste determination petition for a non-hazardous secondary material under the Resource Conservation and Recovery Act (RCRA) and 40 C.F.R. Part 241.
• Prepared a memorandum on the National Organic Program’s (NOP) National List of Allowed and Prohibited Substances, reviewing the petition process to add, remove, or amend the listing of a substance and the National Organic Standards Board’s (NOSB) sunset review procedure.
• Assisted in the review of requirements under the Occupational Safety and Health Administration (OSHA) and the U.S. Department of Transportation (DOT) regarding hazard classifications, and applicable state and local laws and regulations.

Professional & Community Involvement:

Office of the Attorney General for the District of Columbia, Legal Intern for the Commercial Division, 2018

U.S. Environmental Protection Agency, Honors Law Clerk for the Office of Enforcement and Compliance Assurance, 2018

U.S. Department of Justice, Environment and Natural Resources Division, Law Clerk for the Land Acquisition Section, 2017

New York City Office of Administrative Trials and Hearings, Legal Intern, 2017

New York State Department of Environmental Conservation, Region 2 Office, Legal Affairs Intern, 2014

Bar & Court Admissions:

New York State Bar, 2020

District of Columbia Bar, 2020 

U.S. Court of Appeals for the District of Columbia Circuit, 2020 

U.S. Court of Appeals for the Ninth Circuit, 2020