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April 23, 2019

Comments by Lynn L. Bergeson and Kathleen M. Roberts, Included in Bloomberg Environment Article Regarding EPA Chemical Reporting Proposal

The ACTA Group

On April 23, 2019, Bloomberg Environment featured comments by Lynn L. Bergeson, President, The Acta Group (Acta®), and Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), in the article “EPA Proposal May Not Streamline Chemical Reporting After All.”

Attorneys and other industry consultants told Bloomberg Environment the agency’s proposal would be a mixed bag in terms of saved time.


Companies would have to spend time learning new codes under an international system the EPA said it would adopt to file the industrial function, commercial use, and other information about each chemical, said Kathleen Roberts, vice president of Bergeson and Campbell’s Consortia Management LLC.

The proposed rule would also expand how much information on chemical function companies must provide. Chemicals in paint, for instance, can help it stay smooth, add color, or provide a matte or glossy finish.

In the short term, any new Chemical Data Reporting provision would increase burdens for companies that must report, said Lynn Bergeson, managing partner with Bergeson and Campbell PC.


“CDR reporting is hard, and in my view, that is okay if we wish to enable EPA to do its job,” Bergeson told Bloomberg Environment.

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