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On March 23, 2020, comments by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®) were featured by Bloomberg Environment regarding a proposed registration for Polyguard, which uses nanosilver particles to protect textiles from microbes and bacteria. Lynn Bergeson, managing partner of Bergeson & Campbell P.C., said Polyguard’s registration application is much more targeted, for use only on textiles. “It’s also formulated differently,...
March 23, 2020
NGOs File Suit against EPA for Failing to Disclose Information about New Chemical Substances
On March 18, 2020, a coalition of non-governmental organizations (NGO) filed suit in the U.S. District Court for the District of Columbia against the U.S. Environmental Protection Agency (EPA), claiming that EPA fails to disclose information about new chemical substances under the Toxic Substances Control Act (TSCA). According to the plaintiffs’ complaint, EPA fails to publish full and complete notices of its receipt of new chemical applications in a timely fashion and does not disclose...
On March 17, 2020, the U.S. Environmental Protection Agency (EPA) announced the availability of a final rule amending the Chemical Data Reporting (CDR) rule. According to EPA, the amendments are intended to reduce the burden for certain CDR reporters, improve the quality of CDR data collected, and align reporting requirements with the Frank R. Lautenberg Chemical Safety for the 21st Century Act’s (Lautenberg Act) amendments to the Toxic Substances Control Act (TSCA). EPA states that...
On March 18, 2020, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding a lawsuit brought against the U.S. Environmental Protection Agency (EPA) saying the agency failed to provide information about chemical use and new chemicals to which the public is legally entitled. “I do not question the plaintiffs’ goals—EPA has a clear obligation and should re-commit to meeting those...
On March 18, 2020, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding a lawsuit brought against the U.S. Environmental Protection Agency (EPA) saying the agency failed to provide information about chemical use and new chemicals to which the public is legally entitled. “I do not question the plaintiffs’ goals—EPA has a clear obligation and should re-commit to meeting those...
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Christopher R. Blunck has joined our firms as Of Counsel with B&C and Senior Regulatory Specialist with Acta. Mr. Blunck most recently served as Policy Analyst and Special Assistant to the Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT). Mr. Blunck has managed or participated in the development of hundreds of Toxic Substances...
March 9, 2020
EPA Releases Supplemental Proposed Rule to the Proposed Rule on Strengthening Transparency in Regulatory Science
On March 3, 2020, the U.S. Environmental Protection Agency (EPA) announced the availability of a supplemental notice of proposed rulemaking (SNPRM) to the Strengthening Transparency in Regulatory Science proposed rule. EPA notes that the SNPRM “is not a new rulemaking; rather, it provides clarifications on certain terms and aspects of the 2018 proposed rule.” The SNPRM: Proposes that the scope of the rulemaking applies to influential scientific information, as well as significant...
March 4, 2020
EPA Plans to Provide Additional Clarification on Self-Identifying as a Manufacturer or Importer of a High-Priority Chemical
Given the considerable industry stakeholder confusion and angst that has arisen related to the January 27, 2020, U.S. Environmental Protection Agency (EPA) Federal Register notice on identifying the preliminary lists of manufacturers (including importers) of the 20 chemical substances that EPA designated as high-priority substances for risk evaluation and for which fees will be charged (85 Fed. Reg. 4661), EPA leadership has repeatedly stated that EPA is considering options to...
Today as never before, the old adage “there is strength in numbers” rings true. As the U.S. Environmental Protection Agency (EPA) continues to implement the amended Toxic Substances Control Act (TSCA), industry stakeholders are recognizing the immense importance of working within consortia to leverage resources, reduce cost, and increase opportunities for successful results. EPA statements in connection with TSCA implementation have repeatedly reinforced its expectation that industry will...
In a recent Bergeson & Campbell, P.C. (B&C®) advisory memorandum, we noted that enforcement activity under the Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) has been increasing during the last couple of years. That memorandum provides guidance to TSCA stakeholders on how to respond to a typical U.S. Environmental Protection Agency (EPA) TSCA inspection letter, and notes that it is often unclear why a particular manufacturer...