All ACTA News

August 5, 2022
Webinar Recording Available: “TSCA New Approach Methodologies”
The Acta Group (Acta®) affiliate Bergeson & Campbell, P.C.’s (B&C®) August 3, 2022, webinar “TSCA New Approach Methodologies” is now available for on-demand viewing at https://attendee.gotowebinar.com/recording/8166994675079284995.   During this one-hour webinar, panelists shared a comprehensive review of the U.S. Environmental Protection Agency’s (EPA) use of New Approach Methodologies (NAM) in evaluating chemicals under the Toxic Substances Control Act (TSCA). Kristie Sullivan, MPH, Vice President of Research Policy with the Physicians ... read more >
August 4, 2022
Lynn L. Bergeson Earns High Accolades from Chambers, WWL, and Best Lawyers
Bergeson & Campbell, P.C. (B&C®) is pleased to announce that Managing Partner Lynn L. Bergeson has been recognized by a number of the leading legal ranking, and peer and client review organizations, notably Chambers and Partners, Best Lawyers, and Who’s Who Legal. Ms. Bergeson was awarded the highest ranking attainable, Band 1, in Chambers USA Guide 2022. This is Ms. Bergeson’s 18th year earning top marks from Chambers USA as one of the best lawyers in America. The commentary accompanying her Chambers ranking speaks of Ms. Bergeson as “The best nationwide ... read more >
July 22, 2022
Richard E. Engler, Ph.D., Quoted by Bloomberg Law in Article “Cutting Industry Negotiation Said to Speed EPA Chemical Controls”
On June 29, 2022, Bloomberg Law quoted Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®), discussing the use of chemical consent orders to speed up the new chemical review process. Directly issuing orders would not resolve all the delays new chemical manufacturers experience, said Richard Engler, director of chemistry for Bergeson & Campbell, PC. The EPA’s new chemicals office already has negotiated nearly 200 consent orders for new chemicals, he said. But the manufacturers of those new chemicals can’t fully distribute them as ... read more >
July 22, 2022
Lynn L. Bergeson Quoted by Bloomberg Law in Article “Three Lawsuits Aim to Shape EPA’s Use of Chemical Test Orders”
On July 22, 2022, Bloomberg Law quoted Lynn L. Bergeson, President, The Acta Group (Acta®), regarding three lawsuits that challenge the US Environmental Protection Agency’s (EPA) authority to order chemical manufacturers to generate information on their products. “The Lanxess and Vinyl Institute cases are, to me, a predictable result of a chaotic rollout of EPA Section 4 Test Order efforts,” said Lynn L. Bergeson, managing partner with Bergeson & Campbell PC, which specializes in chemical regulations implemented by multiple agencies. TSCA ... read more >
July 12, 2022
Lynn L. Bergeson Quoted by Chemical Week in Article “Supreme Court curbs EPA’s ability to regulate power plant emissions”
On July 11, 2022, Chemical Week quoted Lynn L. Bergeson, President, The Acta Group (Acta®), regarding a Supreme Court ruling that limits the US Environmental Protection Agency’s (EPA) authority to combat climate change by regulating emissions from existing power plants. Legal experts say the decision could have broader implications for EPA’s ability to regulate chemicals. “The Court seems to have put a name to what some believe is a pretext for conservative courts to blunt agency action on the grounds the text does not allow for a particular ... read more >
July 6, 2022
Register Now for “TSCA New Approach Methodologies”
Wednesday, August 3, 2022 12:00 p.m. - 1:00 p.m. (EDT) Register Today The 2016 amendments to the Toxic Substances Control Act (TSCA) require the U.S. Environmental Protection Agency (EPA) “to reduce and replace” vertebrate animals to the extent practicable, scientifically justified, and consistent with TSCA policies. EPA is also required to “develop a strategic plan to promote the development and implementation of alternative test methods and strategies to reduce, refine, or replace vertebrate animal testing and provide information of equivalent or better scientific ... read more >
June 27, 2022
All Things Chemical® Podcast Presents “Balancing Wildlife Protection and Responsible Pesticide Use -- A Conversation with EPA’s Jake Li
The latest episode of Bergeson & Campbell, P.C.’s (B&C®) All Things Chemical® podcast, “Balancing Wildlife Protection and Responsible Pesticide Use -- A Conversation with Jake Li,” features a conversation with Jake Li, Deputy Assistant Administrator for Pesticide Programs, Office of Chemical Safety and Pollution Prevention (OCSPP), U.S. Environmental Protection Agency (EPA). Conversation topics include what the Administration is doing to balance wildlife protection and responsible pesticide use and how the Endangered Species Act (ESA) Workplan is helping ... read more >
June 2, 2022
Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “TSCA: EPA unlikely to defer risk management to other federal agencies”
On May 31, 2022, Richard E. Engler, Ph.D., Director of Chemistry with The Acta Group (Acta®), was quoted by Chemical Watch regarding a recent proposed Toxic Substances Control Act (TSCA) risk management rule that provides insights into the potentially limited extent to which the U.S. Environmental Protection Agency (EPA) will defer to other agencies, despite concern from industry that this could lead to duplicative requirements. Richard Engler, director of chemistry at law firm Bergeson & Campbell, said he expects the agency will be open to stakeholder comments on ... read more >
June 1, 2022
Register Now for "TSCA Reform -- Six Years Later" on June 29, 2022
The Acta Gruop (Acta®) affiliate Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health are pleased to present “TSCA Reform - Six Years Later.” This complimentary virtual conference marks the sixth Toxic Substances Control Act (TSCA) Annual Conference, reflecting on the accomplishments and challenges since the implementation of the 2016 Lautenberg Amendments and where TSCA stands today. Speakers will dive into a host of topics, including the interface of science and ... read more >
May 27, 2022
Lynn L. Bergeson Quoted by Bloomberg Law in Article “First Lawsuit Challenging EPA’s Chemical Test Order Filed”
On May 26, 2022, Bloomberg Law quoted Lynn L. Bergeson, President, The Acta Group (Acta®), regarding a lawsuit filed by a coalition of companies making a solvent that the U.S. Environmental Protection Agency’s (EPA) is examining for possible regulation. The coalition is asking a federal court to overturn an agency order seeking data to understand whether the chemical could harm wildlife.  Lynn L. Bergeson, managing partner of Bergeson and Campbell PC, which specializes in chemical regulations, said she couldn’t comment on the case’s ... read more >
May 23, 2022
Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “TSCA asbestos proposal to put cost-benefit considerations under the microscope”
On May 20, 2022,  Richard E. Engler, Ph.D., Director of Chemistry with The Acta Group (Acta®), was quoted by Chemical Watch regarding the U.S. Environmental Protection Agency's (EPA) proposal to ban all ongoing uses of chrysotile asbestos, including a two-year deadline for the chlor-alkali industry to stop using asbestos diaphragms in the production of chlorine. The 12 April proposal – the first issued under the amended TSCA in response to a completed risk evaluation – floats what the agency calls an "aggressive transition" away ... read more >
May 20, 2022
Webinar Recording Available: “Domestic Chemical Regulation and Achieving Circularity”
The Acta Group (Acta®) affiliate Bergeson & Campbell, P.C.’s (B&C®) May 18, 2022, webinar “Domestic Chemical Regulation and Achieving Circularity” is now available for on-demand viewing at https://attendee.gotowebinar.com/recording/2013797750853340422. During this one-hour webinar, Lynn L. Bergeson, President, Acta, moderated a timely and fascinating review of the state of sustainable chemical regulation in the United States with Kate Sellers, Technical Fellow, ERM; Mathy Stanislaus, Vice Provost, Executive Director, The Environmental Collaboratory, Drexel ... read more >
April 21, 2022
Recording Available: “FIFRA Hot Topics”
Bergeson & Campbell, P.C.’s (B&C®) April 20, 2022, webinar “FIFRA Hot Topics” is now available for on-demand viewing at https://attendee.gotowebinar.com/recording/7426709986449689102. During this one-hour webinar, Lisa M. Campbell, Partner, B&C, moderated a lively and informative discussion between Edward Messina, Director, U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP), and James V. Aidala, Senior Government Affairs Consultant, B&C, as they discussed key OPP developments and priorities.   With year one of the Biden ... read more >
April 6, 2022
Lynn L. Bergeson Quoted by Chemical Watch in Article “How the US EPA has fired a ‘warning shot’ on enforcement of PFAS requirements”
On April 5, 2022, Chemical Watch quoted Lynn L. Bergeson, President, The Acta Group (Acta®), regarding the U.S. Environmental Protection Agency’s (EPA) recent policy interpretation on the fluorination of high-density polyethylene (HDPE) containers. [‌I]n some respects, there has been little surprise at the agency’s view that the generation of certain PFASs during the fluorination of polyolefins – including polyethylene – is an activity covered under the 2020 long-chain perfluoroalkyl carboxylate (LCPFAC) TSCA significant new use rule (Snur). The ... read more >
April 5, 2022
Recording Available: “UK REACH, What’s Happened and What’s Next?”
The Acta Group’s (Acta®) March 23, 2022, webinar “UK REACH, What's Happened and What's Next?” is now available for on-demand viewing at https://attendee.gotowebinar.com/recording/815913916012295937. During this 1-hour webinar, Lynn L. Bergeson, President, Acta; Steven P. Brennan, Ph.D., Senior Manager, REACH, Acta; and Jane S. Vergnes, Ph.D., DABT®, Vice President, Scientific Affairs and Director of Toxicology, Acta discussed the significant implications for chemical regulatory compliance under the United Kingdom (UK) REACH ... read more >
April 4, 2022
Lynn L. Bergeson Quoted in Bloomberg Law Article “White House to Define ‘Sustainable Chemistry’ as EU Demands It”
On April 1, 2022, an article written by Lynn L. Bergeson, President, The Acta Group (Acta®), was referenced by Bloomberg Law regarding the White House's efforts to define "sustinable chemistry." The quoted article, "Don’t Ignore Game-Changing EU Environmental Initiatives," discusses noteworthy European Union (EU) chemical regulatory and policy initiatives that are expected to impact U.S. chemical stakeholders.   The White House wants help defining “sustainable chemistry” in an effort that ... read more >
April 1, 2022
TSCA New Chemicals Coalition Quoted in Chemical Watch Article “Companies call for EPA to keep TSCA inventory corrections process”
On March 31, 2022, Chemical Watch reported on a letter written by the TSCA New Chemicals Coalition (NCC) calling on the U.S. Environmental Protection Agency (EPA) to suspend its plans to revoke a decades-old policy allowing companies to request corrections to the TSCA inventory.  The TSCA New Chemicals Coalition – an ad hoc group represented by the law firm Bergeson & Campbell – said scrapping the process could give rise to a host of unintended consequences. It also questioned the legality of the agency making the change without an ... read more >
March 28, 2022
Richard E. Engler, Ph.D., Quoted in Bloomberg Law Article “Chemical Makers Ask EPA to Fix, Not Drop, Corrections Policy”
On March 25, 2022,  Richard E. Engler, Ph.D., Director of Chemistry with The Acta Group (Acta®), was quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency's (EPA) plan to no longer process chemical manufacturers’ requests to correct the specific ways chemicals on the Toxic Substances Control Act (TSCA) inventory are identified. If the EPA is concerned that companies are using correction requests to add new chemicals to the inventory, it could issue guidance describing the information needed to support a correction request, said Richard ... read more >
March 17, 2022
Karin F. Baron, MSPH, Elected to Society for Chemical Hazard Communication Board of Directors
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Karin F. Baron, MSPH, has been elected to the Board of Directors of the Society for Chemical Hazard Communication. Ms. Baron, a Senior Regulatory Consultant with B&C and Acta, will serve a two-year term. Ms. Baron has participated as an active member of SCHC for the past 20 years; she is the immediate past Chair of the Professional Development Committee. We are especially pleased that Ms. Baron’s leadership and vast subject matter expertise has been recognized and rewarded with ... read more >
March 15, 2022
Acta affiliate B&C Quoted in Chemical Watch Article “Plan to exclude PPE from TSCA risk evaluations sparks industry outcry"
On March 14, 2022, The Acta Group (Acta®) affiliate Bergeson & Campbell, P.C. (B&C®) was quoted by Chemical Watch on the U.S. Environmental Protection Agency's (EPA) decision to no longer consider personal protective equipment (PPE) use in Toxic Substances Control Act (TSCA) risk evaluations.  Law firm Bergeson & Campbell said assuming PPE will not be used, including in cases where required by the Occupational Safety and Health Administration (Osha), "is not based on reasonably available information, impermissibly assumes ... read more >
March 15, 2022
Lynn L. Bergeson Quoted in Chemical Watch Article “Stakeholders clash over chlor-alkali restrictions under imminent TSCA asbestos rule"
On March 14, 2022, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch regarding conflicting visions for the upcoming asbestos Toxic Substances Control Act (TSCA) risk management rule. Lynn Bergeson, managing partner at law firm Bergeson & Campbell, told Chemical Watch the EPA must look at the availability of "technically and economically feasible alternatives that benefit health or the environment" when adopting risk management rules to reduce unreasonable risk identified in evaluations. "There is no ... read more >
March 2, 2022
Lynn L. Bergeson Quoted in Chemical Watch Article “EPA to scrap TSCA inventory corrections process"
On March 1, 2022, Lynn L. Bergeson, President, The Acta Group (Acta®), was quoted by Chemical Watch responding to the U.S. Environmental Protection Agency's (EPA) announcement that it will no longer allow companies to request corrections to the Toxic Substances Control Act (TSCA) inventory and instead require them to submit a pre-manufacture notice (PMN) for improperly identified substances.   The decision "is entirely unprincipled and based on a flawed understanding of the correction process and its continuing utility," said Lynn ... read more >
March 2, 2022
Career Opportunity—Regulatory Specialist—Acta UK Office
Acta is seeking a regulatory affairs professional to join our UK consulting group.  The ideal candidate will be educated preferably in the biological sciences, chemistry, and/or toxicology fields with a strong knowledge of and experience in international chemical regulatory affairs, i.e., industrial, pesticides/biocides, and fertilisers.  Experience in regulatory compliance in industry or consulting is preferred. This position will be based in our Manchester, England location, although telework arrangements may be considered for the right candidate. The Regulatory Specialist will ... read more >
March 1, 2022
Richard E. Engler, Ph.D., Quoted in Bloomberg Law Article "EPA Drops Policy Chemical Makers Use to Correct Critical List"
On Feburary 28, 2022, Richard E. Engler, Ph.D., Director of Chemistry with The Acta Group (Acta®), was quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency's (EPA) announcement that, as of April 26, it will no longer process chemical manufacturers’ requests to correct the specific ways chemicals on the Toxic Substances Control Act (TSCA) inventory are identified. If the EPA is concerned that companies are using correction requests to add new chemicals to the inventory, it could issue guidance describing the information needed to ... read more >
February 16, 2022
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted by Inside TSCA in “Industry Sees NAMs Aiding New Chemical Reviews, But Laments PPE Delays"
On February 15, 2022, Lynn L. Bergeson, President, The Acta Group (Acta®), and Richard E. Engler, Ph.D., Director of Chemistry, Acta, were quoted by Inside TSCA regarding the U.S. Environmental Protection Agency's (EPA) application of new approach methods (NAMs) and category-based analyses for new-chemical reviews.  An industry attorney says EPA’s application of new approach methods (NAMs) and category-based analyses for new-chemical reviews is helping some substances move through the TSCA process quickly and in a “predictable” way, ... read more >
February 14, 2022
Register Now for "UK REACH, What's Happened and What's Next?"
Wednesday, March 23, 2022 11:00 a.m. - 12:00 p.m. (EDT)/15:00 - 16:00 (GMT) Register Today Companies worldwide must be aware of the significant implications for chemical regulatory compliance under the United Kingdom (UK) REACH regulation as the UK has completed its first year of complete separation from the European Union (EU). While the major regulations pertaining to chemicals were carried over into UK law mostly unchanged after the Brexit transition period, the UK now makes its own decisions, and divergence between the UK and EU regulations will continue in 2022 and ... read more >
January 24, 2022
Chemical Watch Quotes Richard E. Engler, Ph.D., Regarding CBI Claim Issues
On January 24, 2022, Chemical Watch quoted Richard E. Engler, Ph.D., Director of Chemistry with The Acta Group (Acta®), in the article "Proposal on the horizon to update TSCA confidentiality procedures." According to Richard Engler, director of chemistry at industry law firm Bergeson & Campbell and a 17-year veteran of the EPA, this could be aimed at ensuring the agency can get in touch with CBI claim holders.   "One of the challenges EPA faces is maintaining contact with submitters so that when CBI claims sunset after ten years, EPA can ... read more >
January 5, 2022
Register Now for “What to Expect in Chemicals in 2022”
2022 will bring competing priorities for the U.S. Environmental Protection Agency (EPA) for which companies should now prepare. The Acta Group (Acta®) affiliate Bergeson & Campbell, P.C. (B&C®) is pleased to present “What to Expect in Chemicals in 2022,” a webinar offering our best informed judgment as to the trends and key developments B&C’s legal, scientific, and regulatory professionals expect to see in 2022. These include consequential policy shifts reflecting the Biden Administration’s “all of government” commitment to ... read more >
January 3, 2022
The Acta Group Releases 2022 Forecast for U.S. Federal and International Chemical Regulatory Policy
Bergeson & Campbell, P.C. (B&C®) and its consulting affiliate The Acta Group (Acta®) and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to offer you our Forecast 2022. The extraordinary diversity and complexity of global industrial, agricultural, and biocidal chemical initiatives in which our clients engage are reflected in the detailed summary that follows, prepared by the legal, scientific, and regulatory professionals of B&C, Acta, and BCCM. In this comprehensive overview, we offer our best informed judgment as to the trends ... read more >
December 15, 2021
Lynn L. Bergeson and Christopher R. Blunck Quoted by Bloomberg Law in “EPA to Miss Chemical Deadlines, Exposing Public to Risks”
On December 14, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), and Christopher R. Blunck, Senior Regulatory Specialist, Acta, were quoted by Bloomberg Law regarding the U.S. Environmental Protection Agency’s (EPA) recently released regulatory agenda that “anticipates the agency missing at least five of 10 deadlines the 2016 Toxic Substances Control Act (TSCA) amendments set to restrict too-risky chemicals already on the U.S. market" and "offers no timeline to comply with a 2017 appropriations bill requirement to redefine housing ... read more >
December 13, 2021
Richard E. Engler, Ph.D., Quoted by Bloomberg Law in “EPA Stops Posting ‘Critically Important’ Chemical Risk Data”
On December 13, 2021, Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®) was quoted by Bloomberg Law regarding a substantial decrease in chemical data being posted to the ChemView database by the U.S. Environmental Protection Agency (EPA) due to resource constraints. This information is used by the public, industry, and environmental groups to easily access health and safety information for hundreds of chemicals. Businesses might need the information to decide whether to purchase a chemical, design an alternative, or improve its health and safety ... read more >
November 29, 2021
Lynn L. Bergeson and Richard E. Engler, Ph.D., Quoted by Bloomberg Law in “Chemical Makers Face First of Two EPA Fee Hikes”
On November 24, 2021, Lynn L. Bergeson, President, The Acta Group (Acta®), and Richard E. Engler, Ph.D., Director of Chemistry, Acta, were quoted by Bloomberg Law regarding planned increases for Toxic Substances Control Act (TSCA) fees.  Lynn L. Bergeson, managing partner, with Bergeson and Campbell PC, said EPA’s fee revisions will be the “main event” for companies to watch. Tuesday’s announcement appears to be the statute’s routine adjustment to fees for inflation, said Richard Engler, director of chemistry for the same law ... read more >
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 of law firm Bergeson & Campbell said. Requiring companies to submit a significant new use notice (Snun) ... read more >
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 TSCA’s preemption provision “works on paper, but rarely works in ... read more >
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 examining the huge variety of PFASs as one class and as single compounds, avoiding over- or ... read more >
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 and a Circular Economy" session of the ABA Section of Environment, Energy, and ... read more >
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 delays are reminiscent of the ‘backlog’ days of 2017 when ... read more >
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 that should not detract from Richard’s invaluable contributions and his ... read more >
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. Engler, Ph.D.   Do you wonder if the PFAS reporting rules extend to domestically-produced ... read more >
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 assertions" that more time was needed to comply, it said in its 3 September ... read more >
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 situation.  Lynn Bergeson, managing director at Bergeson & Campbell, said that ... read more >
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 Environmental Toxicology, and Masters and Bachelors degrees in Entomology and Genetics. Dr. Zhuang, ... read more >
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 provided 100 pages worth of data showing the chemical was safe and needed no ... read more >
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 companies and trade associations on TSCA compliance, said the agency is aware of and sensitive to "the ... read more >
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 substance that is a perfluoroalkyl or polyfluoroalkyl substance in any year since 1 ... read more >
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 looking at the research from domestic and international agencies. "The FDA may revoke ... read more >
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, "the passage of a modest amount of time has not moved the needle appreciably," she ... read more >
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 the chemicals might harm people or the environment. Others are concerned that the Biden EPA is ... read more >
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), perchloroethylene (PERC), and 1-4 dioxane—along with the cyclic aliphatic bromide cluster (HBCD), a group of three ... read more >
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 proposed rule’s absence of limits or conventional exemptions is "not precedented", he ... read more >
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