All Knowledge & Insights By Date

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...

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...

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...

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...

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 of...

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...

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 2016...

On January 10, 2017, Bloomberg BNA Daily Environment Report quoted The Acta Group (Acta®) Vice President of Policy and Government Affairs Consultant James V. Aidala regarding a recent U.S. Environmental Protection Agency (EPA) risk assessment. The risk assessment also could be a sign of how the EPA will address the suite of organophosphate pesticides slated for review later this year, including chlorpyrifos and malathion. Industry groups are concerned this could...

On January 9, 2017, Richard E. Engler, Ph.D., Senior Chemist with The Acta Group (Acta®), was quoted in “The Chemical Industry’s Having a Bad Reaction to New Regs.” As a result, some chemists feel like they must dial back their ambitions to pass review. “New chemicals are taking significantly longer to get through the EPA process now,” says Rich Engler, a chemical consultant with environmental law firm Bergeson & Campbell. “If I were advising a client I would tell them to...

On January 4, 2017, the White House announced the release of the 2017 Update to the Coordinated Framework for the Regulation of Biotechnology.  The 2017 Update provides a comprehensive summary of the roles and responsibilities of the U.S. Environmental Protection Agency (EPA), the U.S. Food and Drug Administration (FDA), and the U.S. Department of Agriculture (USDA) with respect to regulating biotechnology products.  Together with the National Strategy for Modernizing the...