May 28, 2014
Inside EPA features B&C commentary in “Legal Limit May Drive Novel Voluntary Plan In EPA’s TSCA Fracking Rule.”
“In a May 20 analysis of the ANPR, the law firm Bergeson & Campbell also flags the ‘processors’ issue, saying the notice raises a host questions relating to ‘significant and difficult legal, procedural and policy issues. Noting that the ANPR includes service companies in its discussion of the companies that may be subject to Section 8 reporting, which ordinarily would not apply to ‘users,’ the analysis says, that though such service providers may ‘process’ the chemical while...