November 23, 2021

Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted by Chemical Watch in “TSCA approach for addressing abandoned PFASs may invite criticism”

On November 23, 2021, Chemical Watch featured comments by Lynn L. Bergeson, President, The Acta Group (Acta®) and Richard E. Engler, Ph.D., Director of Chemistry, Acta, regarding a U.S. Environmental Protection Agency (EPA) plan to use Toxic Substance Control Act (TSCA) significant new use rules (SNUR) to address inactive per- and polyfluoroalkyl substances (PFAS). "The Snur authority is a de facto bar to manufacture/import," Lynn Bergeson and Rich Engler...
November 11, 2021

James V. Aidala Quoted in Inside TSCA Article “Former Official Says PFAS Patchwork Shows Failures Of TSCA Preemption”

On November 11, 2021, James V. Aidala, Vice President, Policy and Government Affairs, The Acta Group (Acta®), was quoted by Inside EPA’s Inside TSCA regarding state regulations of per- and polyfluoroalkyl substances (PFAS). A former EPA toxics chief says Michigan’s new executive order limiting purchases of products made with per- and polyfluoroalkyl substances (PFAS) not only expands a nationwide patchwork of state-level PFAS policies, but shows that the reformed...
November 9, 2021

Chemical Watch Article “Stakeholders see room for improvement in US EPA’s PFAS categorization” Features Comments by Richard E. Engler, Ph.D.

On November 9, 2021, Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®), was quoted by Chemical Watch regarding the U.S. Environmental Protection Agency’s (EPA) classification of per- and polyfluoroalkyl substances (PFASs) for company-funded testing under the Toxic Substances Control Act (TSCA). According to Richard Engler, director of chemistry for law firm Bergeson & Campbell, the agency has "come down somewhere in the middle" between...
October 14, 2021

Lynn L. Bergeson Quoted in Bloomberg Law Article “EPA Strategy Coming to Combat Plastic Pollution, Boost Recycling”

On October 14, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency's (EPA) plan to release a national strategy to reduce plastic waste, improve recycling, and boost the market for recycled goods. Ms. Bergeson discussed these issues during the "Moving Towards “Cradle-to-Cradle”: Regulatory Drivers and Barriers in Reducing Waste and Achieving Sustainable Lifecycle Management...
October 7, 2021

Chemical Watch Features Comments by Richard E. Engler, Ph.D., Regarding Delays in the TSCA New Chemicals Review Process

On October 7, 2021, Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®), was quoted by Chemical Watch in the article “TSCA new chemicals review process has ground to a halt, say industry groups.” The TSCA new chemicals review process has "slowed dramatically" over the past year, according to trade groups and industry attorneys, a development they say poses a threat to innovation and the introduction of sustainable chemicals. […] "The current...
September 30, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “US EPA science policy director to head TSCA advocacy for influential NGO”

On September 30, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding Richard Denison’s announcement that he is retiring from the  Environmental Defense Fund (EDF) after nearly 35 years. Lynn Bergeson, managing director at Bergeson & Campbell, expressed her appreciation for Dr Denison’s career. "He has made invaluable contributions to the law, science, and policy of TSCA, on which we may on occasion disagree, but...
September 22, 2021

PFAS Reporting Rules Webinar Recording and Q&A Document Available Now

The Acta Group (Acta®) affiliate Bergeson & Campbell, P.C. (B&C®) is pleased to offer the recording, slides, and written Question and Answer (Q&A) document from our “PFAS Reporting Rules -- What Every Company Needs to Know” webinar, focusing on the U.S. Environmental Protection Agency’s (EPA) proposed reporting rules for per- and polyfluoroalkyl substances (PFAS), presented by B&C Managing Partner Lynn L. Bergeson and Director of Chemistry Richard E....
September 14, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “EPA’s timeline to rework TSCA PBT rules ‘impossible to justify’, NGOs say”

On September 14, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding criticism of the U.S. Environmental Protection Agency’s (EPA) decision to grant industry additional time to comply with a Toxic Substances Control Act (TSCA) prohibition on phenol, isopropylated phosphate (3:1) – or PIP (3:1) – in articles.  Some in industry, however, argue the approach represents the agency’s best effort in a tricky...
September 14, 2021

Chemical Watch Features Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., Regarding Compliance Challenges of EPA’s PIP Rule

On September 14, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®) and Richard E. Engler, Ph.D., Director of Chemistry, Acta, were quoted by Chemical Watch in the article “US EPA ‘turns up the heat’ on industry to demonstrate PIP rule challenges.” The EPA, however, has made clear that it will not give [companies] further time lightly.  Many commenters "did not provide sufficiently specific information about their operations to support their...
September 10, 2021

Meibao Zhuang, Ph.D., Joins Bergeson & Campbell, P.C. and The Acta Group Agricultural Chemicals Practices

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Meibao Zhuang, Ph.D., has joined our firms as Senior Scientist and Regulatory Consultant. Dr. Zhuang offers clients in-depth scientific knowledge and exceptional skills in global and regional regulatory strategy honed over a nearly 20-year career leading regulatory efforts with Corteva Agriscience (Corteva) and Dow AgroSciences LLC (Dow). Dr. Zhuang is a research scientist with a Ph.D. in...
August 12, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “Industry awaits US EPA’s next steps as pause on PIP 3:1 enforcement nears end”

On August 11, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding the possibility that the U.S. Environmental Protection Agency (EPA) will extend compliance dates for Toxic Substances Control Act (TSCA) prohibitions on phenol, isopropylated phosphate (3:1) (PIP (3:1)) before a pause on enforcement is set to expire early next month.  Lynn Bergeson, a partner with Bergeson & Campbell who advises...
August 12, 2021

Richard E. Engler, Ph.D., Quoted in Bloomberg Law Article “Plunge in New Chemical Requests Hurts Innovation, Lawyers Say”

On August 12, 2021, Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®), was quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency’s (EPA) review process for new chemicals. Richard E. Engler, who directs chemistry at Bergeson and Campbell PC, said the EPA still decided to regulate a new chemical after concluding it would pose “no unreasonable risk"—the safest conclusion the agency can reach. Engler said his client...
August 11, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “Industry presses US EPA to scale back PFAS reporting rule”

On August 11, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding the compliance challenges of the U.S. Environmental Protection Agency’s (EPA) proposed per- and polyfluoroalkyl substances (PFAS) reporting rule. The language of the NDAA limits the EPA’s ability to make certain changes. For example, it says a final rule must be issued by 1 January 2023, and reporting must cover "each person who has manufactured a chemical...
July 29, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “US FDA scrutinising fluorinated plastic food containers”

On July 28, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding a U.S. Food and Drug Administration (FDA) plan to evaluate fluorinated plastic food containers for potential per- and polyfluoroalkyl substance (PFAS) contamination.  The FDA said that while companies must fulfil "strict data requirements" to demonstrate non-hazardous conditions of use before approval, it reassesses risks as knowledge advances, such as by...
July 12, 2021

Lynn L. Bergeson Quoted in Chemical Watch Article “Fujifilm discontinues US sales of PIP 3:1-containing film”

On July 8, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding a U.S. Environmental Protection Agency (EPA) plans to begin enforcing PIP 3:1 prohibitions in September. Many businesses and their supply chains were "caught flat-footed" by the restrictions, said Lynn Bergeson, a partner with Bergeson & Campbell who advises companies and trade associations on TSCA compliance and the regulation of chemicals. At the same time,...
July 8, 2021

Lynn L. Bergeson Quoted in Bloomberg Law Article “Chemical Reviews Will Ensure Worker Safety, EPA Toxics Head Says”

On July 7, 2021, Bloomberg Law featured comments by Lynn L. Bergeson, President, The Acta Group (Acta®) regarding a U.S. Environmental Protection Agency (EPA) announcement of policies to review the first round of chemical analyses that were performed under the 2016 amendments to the Toxic Substances Control Act (TSCA). The Biden administration is concerned the Trump administration’s policies to examine chemicals’ risks led to conclusions that ignored too many ways...
July 1, 2021

Comments Made by Lynn L. Bergeson, Michal Freedhoff, Ph.D., and More during TSCA Reform Conference Featured in Bloomberg Law Article “EPA to Revisit Whether Eight Chemicals Too Risky for People”

On June 30, 2021, Bloomberg Law featured quotes from the TSCA Reform – Five Years Later conference regarding a U.S. Environmental Protection Agency (EPA) plan to revisit whether eight chemicals the agency already examined pose greater risks to workers and communities than the Trump administration found. The eight chemicals are seven solvents—methylene chloride, trichloroethylene (TCE), carbon tetrachloride, n-methylpyrrolidone (NMP), 1-bromopropane (1-BP),...
June 18, 2021

Comments by Christopher Blunck Featured in Chemical Watch Article “Breadth of US EPA’s proposed PFAS reporting rule unprecedented, experts say”

On June 17, 2021, Chemical Watch published insights from Christopher R. Blunck, Senior Regulatory Specialist, The Acta Group (Acta®), regarding a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule that includes downstream users and small businesses with a lack of exemptions for the compounds’ occurrence as byproducts or impurities. That is "an extremely broad reporting requirement", said Christopher Blunck, of counsel with Bergeson & Campbell. The...
June 17, 2021

Lynn L. Bergeson Quoted in Bloomberg Law Article “EPA’s Flame Retardant Rule Offers Chemical Lesson for Businesses”

On April 9, 2021, Bloomberg Law featured comments by Lynn L. Bergeson, President, The Acta Group (Acta®) regarding a U.S. Environmental Protection Agency (EPA) rule restricting industrial uses of a popular flame retardant is causing headaches for equipment manufacturers and demonstrating how the nation’s chemicals law can upend global supply chains. But the Environmental Protection Agency was besieged by industry pleas for help soon after the new administration came...
May 24, 2021

Lynn L. Bergeson Quoted by Law 360 in “4 Ways Biden Is Making Headway On Chemical Oversight”

On May 21, 2021, Law 360 quoted Lynn L. Bergeson, President, The Acta Group (Acta®), regarding some of the first moves of the Biden Administration.  President Joe Biden picked Michal Freedhoff, who helped draft the amendments and worked for the Democrats on the Senate Environment and Public Works Committee during the Trump administration, to lead the agency's Office of Chemical Safety and Pollution Prevention. Freedhoff is already in place at the agency, where she...