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February 28, 2019

Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., included in Bloomberg Environment Article Regarding Worker Safeguards

The ACTA Group

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 chemical manufacturers share experiences with and concerns about the agency’s new chemicals program.

The safety sheets let employers know about chemical hazards they must protect against, he said.


“EPA does a good job of identifying workplace exposures,” said Lynn L. Bergeson, managing partner of Bergeson & Campbell PC in an email.

If consent orders and their corresponding new use rules don’t match, parties can urge EPA to align them as it serves everyone’s interest to have the same controls apply, she said.

On potential inconsistencies, Bergeson said, “I am hard-pressed to classify this issue as a recurrent problem.”

She added that the agency’s policies will continue to evolve as its proposed rules are finalized.

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