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On December 6, 2023, comments by Lynn L. Bergeson and Richard E. Engler, Ph.D. were featured in Chemical Watch's article on the U.S. Environmental Protection Agency’s (EPA) recent proposal to overhaul its 2017 risk evaluation ‘framework’ rule. Lynn Bergeson and Rich Engler of Bergeson & Campbell said their primary concern centres around the proposal to remove scientific definitions like ‘best available science’ and ‘weight of the scientific evidence’ from the...
Category: TSCA
December 5, 2023
TOP TSCA TOPICS: Cumulative Risk, NAMs, Risk Evaluations, CBI, and More!, May 17, 2023 11:00 a.m. – 12:00 p.m. (EDT), via webinar
During this one-hour webinar, Anna B. Lowit, Ph.D., Senior Science Advisor, the U.S. Environmental Protection Agency (EPA) Office of Pollution Prevention and Toxics (OPPT); Richard E. Engler, Ph.D., Director of Chemistry, Acta; and Lynn L. Bergeson, President, Acta, discussed groundbreaking science policy initiatives in furtherance of implementation of the Toxic Substances Control Act (TSCA). As EPA advances New Approach Methodologies (NAM), cumulative risk assessment methodologies, and...
December 5, 2023
HCPA 2023 Annual Meeting, December 3-6, 2023, Fort Lauderdale, FL
HCPA’s Annual Meeting engages on the public policy issues that impact the household and commercial products industry. Thought leaders will discuss legislative and regulatory issues, information related to product registrations, sustainability, and industry trends. Richard E. Engler, Ph.D., Director of Chemistry, Acta, will present on TSCA Section 6 risk management issues....
On December 4, 2023, comments by Lynn L. Bergeson and Christopher Blunck were featured in Chemical Watch's article regarding a TSCA section 5(f) orders prohibiting Texas-based Inhance Technologies from producing certain PFAS when fluorinating plastic containers, a move the company said will threaten its "very existence" and affect thousands of downstream businesses. According to Bergeson & Campbell managing partner Lynn Bergeson, the severity of the remedy (cessation of...
November 30, 2023
Lynn L. Bergeson and Richard E. Engler, Ph.D. Quoted in Chemical Watch Article “TSCA risk evaluation for formaldehyde will follow existing procedural rule”
On December 6, 2023, comments by Lynn L. Bergeson and Richard E. Engler, Ph.D. were featured in Chemical Watch's article on the U.S. Environmental Protection Agency's (EPA) plan to conduct its TSCA risk evaluation of formaldehyde following procedures in its existing risk evaluation ‘framework’ rule, rather than those set out in a recent regulatory proposal. Lynn Bergeson and Richard Engler of law firm Bergeson & Campbell said they were surprised to hear the agency would rely...
On November 24, 2023, the U.S. Environmental Protection Agency (EPA) published a proposed rule that will amend the regulations for decabromodiphenyl ether (decaBDE) and phenol, isopropylated phosphate (3:1) (PIP (3:1)), two of the five persistent, bioaccumulative, and toxic (PBT) chemicals addressed in final rules issued under the Toxic Substances Control Act (TSCA) in January 2021. 88 Fed. Reg. 82287. In the proposed rule, EPA states that after receiving additional comments following the...
November 17, 2023
Lynn L. Bergeson, “EPA Proposes Ban on Trichloroethylene,” Chemical Processing, November 17, 2023.
Unsurprisingly, the U.S. Environmental Protection Agency (EPA) proposed on Oct. 31, to ban all uses of trichloroethylene (TCE) after determining it presents an unreasonable risk of injury to human health under conditions of use pursuant to the Toxic Substances Control Act (TSCA). TCE is widely used in cleaning and furniture-care products, degreasers, brake cleaners and tire repair sealants. Alternatives are available for many uses. The proposed rule would ban TCE’s manufacture, processing...
The U.S. Environmental Protection Agency (EPA) proposed on October 31, 2023, to ban all uses of trichloroethylene (TCE) after determining that it presents an unreasonable risk of injury to human health under its conditions of use as documented in EPA’s November 2020 risk evaluation (2020 TCE RE) and January 2023 revised risk determination (2023 Revised RD) pursuant to the Toxic Substances Control Act (TSCA). 88 Fed. Reg. 74712. According to EPA’s October 23, 2023, press release, TCE is...
The U.S. Environmental Protection Agency (EPA) announced on October 19, 2023, a proposed rule that would amend the procedural framework rule for conducting risk evaluations under the Toxic Substances Control Act (TSCA). Published in the Federal Register on October 30, 2023, the proposed rule states that the purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or...
October 16, 2023
Lynn L. Bergeson, “EPA Issues Final Rule on TSCA PFAS Reporting Requirements,” Chemical Processing, October 16, 2023.
On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released its long-overdue final rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The rule requires reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). As discussed in this article, the final rule is not what many of us expected nor wanted....