All Knowledge & Insights By Date

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to inform our clients and friends of the publication by Bloomberg BNA of EHS Strategies:  The Evolving Landscape of TSCA Reform Implementation, the latest edition of BNA’s quarterly EHS Strategies report.  The report provides a comprehensive analysis of recent Toxic Substances Control Act (TSCA) developments written by many of the key players in the development, passage, and...

On October 25, 2017, Brian Xu, M.D., PH.D., DABT®, toxicologist with Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg BNA Daily Environment Report regarding China’s updated pesticide regulations. China's pesticide regulations were updated in the Agriculture Ministry's Order No. 3, which went into effect Aug. 1, but observers said disparities still exist between that directive and the subsequent Proclamation No. 2569, which details the data...

On October 12, 2017, Lynn L. Bergeson, President, The Acta Group (Acta®), presented at the “Innovative Consumer Products and Legal Risk” breakout session at the 2017 Retail Law Conference in Chicago, Illinois. The Retail Industry Leaders Association’s (RILA) Retail Litigation Center hosts this annual gathering of in-house counsel to cover pressing issues facing the retail industry and provide opportunity for interactive participation in roundtable discussions, Questions and...

On October 15, 2017, California Governor Jerry Brown (D) signed the Cleaning Product Right to Know Act of 2017 (S.B. 258). The new law requires manufacturers of cleaning products to disclose certain chemical ingredients on the product label and on the manufacturer’s website. The online disclosure requirements apply to a designated product sold in California on or after January 1, 2020. The product label disclosure requirements would apply to a designated product...

In August 2017, the California Office of Environmental Health Hazard Assessment (OEHHA) released a Questions and Answers for Businesses (Q&A) document related to its August 28, 2016, adopted revisions to its Proposition 65 (Prop 65) Article 6 regulations covering “clear and reasonable warnings” requirements. Information related to OEHHA’s past actions modifying Prop 65 warning regulations, including the August 28, 2016, adoption and the November 27, 2015, and March 25, 2016,...

On October 1, 2017, the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment’s (OEHHA) regulations amending the content required in Proposition 65 (Prop 65) Notices of Violation involving occupational exposure became effective.  The regulations (found at Title 27 of the California Code of Regulations, Section 25903(b)(2)(E)), first proposed on May 19, 2017, are intended to clarify that the “Special Compliance Procedure Proof of...

KKDIK, Turkey REACH, was published on June 23, 2017, after long delays, and will enter into force on December 23, 2017. Turkey’s Ministry of Environment and Urbanization (MoEU) will make available 13 guidance documents by the end of the year to assist industry with compliance. Guidance documents to be issued by the end of the year will address the following issues, among others: (1) dossier and substance...

On October 6, 2017, Inside EPA quoted a recent memorandum from The Acta Group (Acta®) in the article “EPA wins power to oversee biotech mosquito controls.” EPA and the Food and Drug Administration (FDA) have issued new guidance clarifying that EPA has authority for regulating biotechnology (Bt) products such as genetically modified mosquitoes that are used to control the pests, a step that one industry law firm says will be helpful for navigating a federal...

On October 4, 2017, the U.S. Food and Drug Administration (FDA) announced the availability of final guidance that helps to clarify FDA and U.S. Environmental Protection Agency (EPA) jurisdiction over the regulation of mosquito-related products intended to function as pesticides, including those produced through the use of biotechnology.  The notice was published in the Federal Register on October 5, 2017.  82 Fed. Reg. 46500.  Guidance for Industry...

On September 29, 2017, the U.S. Environmental Protection Agency (EPA) announced the availability of two final test method Standard Operating Procedures (SOP) for evaluating the efficacy of antimicrobials against spores of Clostridium difficile (C. diff).  EPA Microbiology Laboratory Branch (MLB) SOP MB-28:  Procedure for the Production and Storage of Spores of Clostridium difficile for Use in the Efficacy Evaluation of Antimicrobial Agents; and EPA MLB...