December 12, 2025

Lynn L. Bergeson, Hallelujah, EPA Proposes to Narrow Scope of TSCA Section 8(a)(7) PFAS Reporting Rule, Chemical Processing, December 10, 2025.

On Nov. 13, 2025, the U.S. Environmental Protection Agency (EPA) proposed revisions (90 Fed. Reg. 50923) to the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). This column summarizes the proposal and the reasons for it....
October 14, 2025

Lynn L. Bergeson, “Defining Risk: EPA Seeks Major TSCA Chemical Evaluation Reforms,” Chemical Processing, October 13, 2025.

On Sept. 23, 2025, the U.S. Environmental Protection Agency (EPA) proposed highly anticipated amendments to the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA). When conducting a TSCA existing chemical risk evaluation, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or non-risk factors under the conditions of use (COU). As...
August 18, 2025

Lynn L. Bergeson, “What Does a Much Smaller Office of Research and Development Mean?,” Chemical Processing, August 18, 2025.

On July 18, 2025, the U.S. Environmental Protection Agency (EPA) rolled out the “reorganization plan” for its Office of Research and Development (ORD). The plan’s stated goal is to reduce budget expenditures, improve science, and have EPA’s research activities better support the work of EPA’s media offices. The EPA press release refers to the reorganization effort as a continuation of “comprehensive restructuring” that includes a reduction in force (RIF) for the ORD and a...
July 16, 2025

Lynn L. Bergeson, “Leveraging Chemical Data More Efficiently,” PCB007 Magazine, July 2025.

Some truths transcend politics, one being that chemical data holds enduring value and is becoming increasingly essential. In the United States, regardless of which party federally controls the levers of power, it’s clear that chemical manufacturers and their customers must develop and curate robust data portfolios for their chemical inventories. The commercial imperatives driving this are undeniable and gaining traction....
July 14, 2025

Lynn L. Bergeson, “Good News: PFAS Reporting Deadline Postponed,” Chemical Processing, July 14, 2025.

The Minnesota Pollution Control Agency (MPCA) announced recently that it will postpone the Jan. 1, 2026, reporting deadline on products containing intentionally added per- and polyfluoroalkyl substances (PFAS). This is welcome news for businesses that were frantically preparing for the fast-approaching deadline. This column explains the state’s PFAS reporting rule, and summarizes the current, fluid state of play in this state’s evolving PFAS program....
June 17, 2025

Lynn L. Bergeson, “Chemical Policy Crossroads: What Are the Make America Healthy Again Report’s Implications?,” Chemical Processing, June 17, 2025.

In partial response to President Trump’s Feb. 13, 2025, Executive Order (EO) 14212, “Establishing The President’s Make America Healthy Again Commission,” the White House issued on May 22, 2025, “The MAHA Report” (with MAHA an acronym for Make America Healthy Again), titled “Make Our Children Healthy Again: Assessment.” If you have not read it, you should, as it raises, but does not answer, interesting questions for manufacturers of all stripes, especially those whose products...
May 14, 2025

Lynn L. Bergeson, “EPA Outlines Actions to Address PFAS,” Chemical Processing, May 14, 2025.

On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s much anticipated announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” ...
April 16, 2025

Lynn L. Bergeson, “Rethinking Environmental Governance: The Age of Deregulation?,” Chemical Processing, April 16, 2025.

Candidate Trump promised to roll back regulations when he ran for president last campaign cycle. He has claimed deregulation was a hallmark of his first term and that his second term would be even more “deregulatory.” Experts will disagree on whether any one president succeeds in reducing the federal regulatory burden. What we do know is that Trump 2.0 has taken early and aggressive deregulatory measures expected to significantly impact many sectors of the U.S. economy. ...
March 14, 2025

Lynn L. Bergeson, Kelly N. Garson, and Lara A. Hall, “Testing, Testing,” Environmental Forum, March/April 2025.

A key force propelling reform of the Toxic Substances Control Act through Congress in 2016 was a bipartisan belief, shared by the business and environmental communities alike, that the Environmental Protection Agency needs more information to do its job of protecting the American public from adverse effects caused by chemical exposures. After all, it has been domestic policy under TSCA for almost a half century that “adequate information should be developed . . . and that the development of...