ACTA News: Lautenberg Implementation

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 >
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 into office in January, so it took an unusual step. It announced in March that it ... read more >
May 20, 2021
Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “What would substance-wide TSCA risk determinations and other new approaches mean for stakeholders?”
On May 20, 2021, Chemical Watch featured comments by Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®) regarding recent policy shifts signaled by the US EPA on how it conducts TSCA risk evaluations. Incorporating environmental justice considerations "may present a significant analytical challenge if EPA seeks to move beyond a fenceline cumulative exposure approach", for example, if a worker is exposed at work and then through living near that facility, said Richard Engler, director of chemistry at Bergeson & Campbell.  "It is not ... read more >
April 9, 2021
Lynn L. Bergeson Quoted in Chemical Watch Article "EPA prepares to issue TSCA PFAS reporting rule proposal"
On April 9, 2021, Chemical Watch featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule under the Toxic Substances Control Act (TSCA), requiring manufacturers to submit detailed information on these compounds to guide potential regulatory action. The US EPA is nearing completion of a proposed per- and polyfluoroalkyl substance (PFAS) reporting rule under TSCA, requiring manufacturers to submit detailed information on these compounds to guide potential ... read more >
January 28, 2021
Lynn L. Bergeson and Richard E. Engler, Ph.D. Quoted in Chemical Watch Article "TSCA implementation may be ‘significantly different’ under Biden"
On January 28, 2021, Chemical Watch featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C regarding changes to the Toxic Substance Control Act (TSCA) under Biden. "TSCA implementation and interpretation could be significantly different" under the new administration, Lynn Bergeson, managing partner at Bergeson & Campbell, told Chemical Watch. [...] Ms. Bergeson agreed that there is enough ambiguity in the rule to allow for different policy interpretations. "Any ... read more >
January 26, 2021
Comments by Lynn L. Bergeson Featured in Chemical Watch “Global Outlook 2021: Risk assessment and management under TSCA – what should we expect?”
Chemical Watch’s “Global Outlook 2021: Risk assessment and management under TSCA – what should we expect?” includes a conversation between Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Terry Hyland, North America Managing Editor, Chemical Watch, regarding what to expect from the Biden Administration and the U.S. Environmental Protection Agency (EPA) in 2021. Excerpts from the article are below. New challenges also lie ahead for the EPA, still working to update its TSCA fees rule and dealing with legal cases that could bring an ... read more >
January 20, 2021
Comments by Lynn L. Bergeson Discussing Biden Chemical Policy Featured in Bloomberg Environment & Energy Report
On January 20, 2021, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) were featured in the Bloomberg Environment & Energy Report article "Biden Day 1 Presages ‘Far More Aggressive’ Chemicals Stance." Lynn Bergeson, managing partner of Bergeson and Campbell PC, which specializes in chemical policies, saw the selected TSCA rules and policies as focusing on the entire process EPA has used to examine and regulate chemicals through an environmental justice “lens.” That lens will find many problems, she said, ... read more >
January 12, 2021
Richard E. Engler, Ph.D. Quoted in Bloomberg Environment & Energy Report Article "OSHA, EPA to Share Trade Secrets in Joint New Chemicals Work"
On January 12, 2021, Bloomberg Environment & Energy Report featured comments by Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®) regarding an agreement between the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) to share trade secrets about chemicals that manufacturers seek to produce or import. Richard E. Engler, director of chemistry with Bergeson and Campbell PC, said unresolved questions—including who would regulate when—remain. There are situations when either ... read more >
December 23, 2020
Comments by Lynn L. Bergeson and Richard E. Engler, Ph.D., Featured in Bloomberg Environment Article "Fuel-Chemicals Advisory Seen as ‘Unwanted’ EPA Parting Gift”
On December 23, 2020, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) and Richard E. Engler, Ph.D., Director of Chemistry, B&C, were featured by Bloomberg Environment regarding a recent U.S. Environmental Protection Agency (EPA) compliance advisory describing how the Toxic Substances Control Act (TSCA) applies to certain petroleum-based chemicals, along with renewable substitutes made from crops, fats, and waste oil. [T]he EPA’s advisory is also “an unexpected and, to many, unwanted parting gift from the Trump ... read more >
December 17, 2020
Lynn L. Bergeson Quoted in Bloomberg Environment Article “Virus Prompts EPA to Let Chemical Makers Split Risk Analysis Fees”
On December 17, 2020, Bloomberg Environment featured comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) regarding a recent U.S. Environmental Protection Agency (EPA) decision to allow chemical manufacturers to split certain risk evaluation fee payments to the agency. [T]he due date for the second payment offers some clarity for clients, said Lynn L. Bergeson, managing partner of Bergeson and Campbell, PC, which specializes in chemical regulations and policies. “Several of our clients have received invoices, and no surprise there,” she ... read more >
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