All Knowledge & Insights By Date

The U.S. Government Accountability Office (GAO) released on March 6, 2019, a report entitled High-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on High-Risk Areas. GAO’s high-risk program identifies government operations with vulnerabilities to fraud, waste, abuse, and mismanagement, or in need of transformation to address economy, efficiency, or effectiveness challenges. GAO’s report describes the status of high-risk areas and outlines actions necessary...

On March 4, 2019, the U.S. Government Accountability Office (GAO) published a report titled Chemical Assessments:  Status of EPA’s Efforts to Produce Assessments and Implement the Toxic Substances Control Act.  The report describes the extent to which the U.S. Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) Program has addressed identified challenges and made progress toward producing chemical assessments; and assesses whether EPA has...

The U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) routinely reviews and amends the Hazardous Materials Regulations (HMR) to harmonize the HMR with international regulations and standards.  In February 2019, PHMSA’s Office of Hazardous Materials Safety (OHMS) contracted with the Cambridge Systematics (CS) Team to conduct a risk assessment for the transportation of aerosol containers to align U.S. and international regulations. ...

On March 1, 2019, Inside EPA quoted Bergeson & Campbell, P.C.’s (B&C®) Forecast for U.S. Federal and International Chemical Regulatory Policy 2019 regarding ongoing lawsuits that could foreshadow future challenges to the CBI proposal. The law firm Bergeson & Campbell says in its “Forecast 2019” publication that environmentalists' ongoing lawsuit on EPA's “Inventory notification rule … may presage a challenge to the CBI review rule.” The...

ARGENTINA Banned Pesticide Active Ingredient List Updated By Authority: The Administración Nacional de Drogas, Alimentos y Dispositivos Médicos (Argentinian National Administration of Drugs, Foods and Medical Devices; ANMAT) has compiled a list of banned active ingredients (AI) that are found in rodenticides, insecticides, fungicides, and related products. The list, which is not available on the ANMAT website, contains 86 discrete...

On February 28, 2019, Bloomberg Environment featured comments by Lynn L. Bergeson, President, The Acta Group (Acta®), and Richard E. Engler, Ph.D., Director of Chemistry, Acta, in the article “Chemical Law’s Worker Safeguards Ditched by EPA, Advocates Say.” Safety data sheets impose obligations on employers, said Richard E. Engler, director of chemistry for the Bergeson & Campbell PC law firm. The firm manages the TSCA New Chemicals Coalition in which...

The U.S. Food and Drug Administration (FDA) is scheduled to publish a proposed rule in the Federal Register on February 26, 2019, that would put into effect a final monograph for nonprescription, over-the-counter (OTC) sunscreen drug products. The proposed rule describes the conditions under which FDA proposes that OTC sunscreen monograph products are generally recognized as safe and effective (GRASE) and not misbranded. According to FDA’s...

On February 22, 2019, Inside EPA featured comments by Christopher R. Bryant, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), regarding the U.S. Environmental Protection Agency’s (EPA) recently released pharmaceutical waste rule. A former EPA waste official believes the rule will almost certainly draw litigation. “I would bet my one-eyed, drunken dog on it,” says Chris Bryant, a former agency waste official who is now a senior regulatory...

The U.S. Environmental Protection Agency (EPA) released on February 19, 2019, an update of the Toxic Substances Control Act (TSCA) Chemical Inventory (TSCA Inventory), which lists chemicals that are “active” versus “inactive” in commerce in the U.S.  EPA’s News Release states that a “key result of the update is that less than half of the total number of chemicals on the current TSCA Inventory (47 percent or 40,655 of the 86,228 chemicals) are currently in commerce.”...

On February 20, 2019, Inside EPA featured comments by James V. Aidala, Senior Government Affairs Consultant with Bergeson & Campbell, P.C. (B&C®), in the article “New EPA Toxics Chief Seeks To Quell Critics As Agency Implements TSCA.” Jim Aidala, a former EPA toxics chief in the Clinton administration who is now with Bergeson & Campbell, said that Dunn’s confirmation will help the agency navigate its heavy workload in implementing the new law, even as...