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August 15, 2016

Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article On The Need To Submit Thoughtful PMNs to EPA

The ACTA Group

On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, President of The Acta Group (ACTA®), in the article, “Give EPA Detailed New Chemical Notices, Attorneys Advise.”

Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much more strategic, thoughtful and detailed,” Lynn Bergeson, managing partner of Bergeson & Campbell PC said during a July 14 webinar the firm organized.


Both the old and newly amended TSCA say the EPA’s “authority over chemical substances and mixtures should be exercised in such a manner as to not impede unduly or create unnecessary economic barriers to technological innovation,” Bergeson said, referring to Section 2601(b)(3).

The new law makes “very consequential changes” to the new chemicals provisions of TSCA as the EPA will have to carefully balance the requirements imposed by different sections of the law, she said.