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On September 16, 2016, the California Environmental Protection Agency's Office of Environmental Health Hazard Assessment (OEHHA) issued a notice of intent to list perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) as known to the state to cause reproductive toxicity under the Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65). OEHHA is proposing the action under the authoritative bodies' listing mechanism. Comments are...
On September 19, 2016, the U.S. Environmental Protection Agency (EPA) posted a notice on the Chemical Data Reporting website that it has amended the CDR regulations to extend the 2016 submission deadline from September 30, 2016, to October 31, 2016. According to the pre-publication version of the Federal Register notice for the final rulemaking, EPA received a request for an extension, citing problems with certain...
September 15, 2016
CWA: EPA Settlement Telegraphs Changes to General Permit Coverage for Facilities with Coal Tar Sealed Pavement
On August 16, 2016, the U.S. Environmental Protection Agency (EPA) reached a settlement in Clean Water Act (CWA) lawsuits filed over its 2015 Multi-Sector General Permit (MSGP) for Stormwater Discharges from Industrial Activities. 80 Fed. Reg. 34403 (June 16, 2015). The MSGP is the collective term for the CWA National Pollutant Discharge Elimination System (NPDES) program's general permits for stormwater discharges from industrial facilities spanning 29 sectors, including, but not...
September 12, 2016
Charles M. Auer, Former Director of EPA Office of Pollution Prevention and Toxics (OPPT), Joins Bergeson & Campbell, P.C. and The Acta Group
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are very pleased to announce that Charles M. Auer has joined our teams as Senior Regulatory and Policy Advisor. For more than three decades, Mr. Auer has provided sagacious, informed, and deeply insightful guidance on legal, policy, and scientific matters related to the regulation of chemicals under the Toxic Substances Control Act (TSCA) and related domestic and international chemical control laws. Mr. Auer's experience...
The Ministry of the Environment (MOE) published an amended version of the Act for the Registration and Evaluation of Chemicals (K-REACH) enforcement decree and enforcement rules, which have both entered into force. The amendments include some exemptions from reporting for new chemicals, and an extended 14-day grace period for substances used only for research and development (R&D) purposes. The final amendments do not include a proposal to remove a provision that states...
August 25, 2016
B&C Memoranda Featured In Inside EPA Article, “Attorneys Say Proposed TSCA Rule May Violate Trade Secret Provisions”
On August 25, 2016, Acta affiliate Bergeson & Campbell, P.C.’s (B&C®) memoranda “TSCA Reform: Proposed Changes to SNUR Procedures Would, Perhaps Inadvertently, Result in Disclosure of CBI to Third Parties/Possible Competitors” and “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” were discussed in an Inside EPA article on how Toxic Substances Control Act (TSCA) Reform may violate trade...
August 19, 2016
China Implements Requirements For Shipments From Zika-Infected Countries, Including The U.S., And Other Recent Chinese Regulatory Developments
China Implements Requirements For Shipments From Zika-Infected Countries, Including The U.S.: In March 2016, the General Administration of Quality Supervision, Inspection, and Quarantine (AQSIQ) began requiring all countries on its Zika-infected list to comply with disinsection requirements. The United States Department of Agriculture (USDA) Foreign Agricultural Service's (FAS) August 19, 2016, "Update on China's Requirements for Shipments from Zika-Infected...
August 18, 2016
Chemical Watch Article “Law firm flags up issues in EPA Snur proposal” Quotes B&C Memorandum Conflict Between SNURs And Revised OSHA HCS
On August 18, 2016, Chemical Watch quoted Acta affiliate Bergeson & Campbell, P.C.’s (B&C®) memorandum, “TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards,” in an article examining the conflict between the U.S. Environmental Protection Agency’s (EPA) Significant New Use Rule (SNUR) proposal and the revised Occupational Safety and Health Administration's (OSHA) Hazard Communications Standard...
August 15, 2016
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article On The Need To Submit Thoughtful PMNs to EPA
On July 15, 2016, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, President of The Acta Group (ACTA®), in the article, “Give EPA Detailed New Chemical Notices, Attorneys Advise.” Pre-manufacture notifications, or PMNs, that makers must submit before they can produce or import a new chemical, and significant new use notifications, which companies must submit before they can make or use certain chemicals in new ways, “need to be much more strategic,...
On August 11, 2016, the Bloomberg BNA Daily Environment Report quoted Kathleen M. Roberts, Vice President of B&C® Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C. (B&C®) And Acta, on the implication of additional fees created by Toxic Substance Control Act (TSCA) reform. Companies that pay the costs of generating toxicity, exposure and other data should not be “double billed” through additional fees to review the...