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February 9, 2017

Inside EPA Article, “Stakeholders Flag Early Concerns On EPA TSCA Risk Evaluation Proposal,” Quotes B&C Memorandum

The ACTA Group

On February 9, 2017, Inside EPA quoted Acta affiliate Bergeson & Campbell P.C.’s (B&C®) memorandum, “TSCA: EPA Releases Proposed Chemical Risk Evaluation Process under New TSCA,” regarding how a weight of evidence (WoE) approach would impact U.S. Environmental Protection Agency (EPA) risk evaluations.

And a Jan. 19 Bergeson & Campbell memorandum on the proposal says that while the preamble contains language leading toward codifying an effective WoE approach, “A clear statement of EPA’s approach to WOE in conducting risk evaluations would provide a discernible starting point for the development of new guidance for carrying out” the WoE requirements in the new law.

The memo also says that “[o]ne gap that must be filled by EPA in the procedural rule is development of a WOE for exposure assessment, an aspect that was not discussed in the proposal and for which there is no existing EPA model,” citing language in the law that says a risk evaluation shall “describe the weight of the scientific evidence for the identified hazard and exposure.” [subscription required]