All Knowledge & Insights By Date

On July 28, 2016, the U.S. Environmental Protection Agency (EPA) proposed to update the Toxic Substances Control Act (TSCA) Significant New Use Rule (SNUR) procedures. 81 Fed. Reg. 49598. As discussed in our previous memorandum on this proposed rule, Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards, while some of the proposed changes are not consequential, other changes, such as those related to workplace protections, are more clearly...

On August 4, 2016, quotes from 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” were included in an Inside EPA article about conflicts between Occupational Safety and Health Administration (OSHA) and the revised Toxic Substances Control Act (TSCA). A law firm that frequently represents industry clients is warning that a recently...

SWA Announces New Chemical Database: On July 5, 2016, Safe Work Australia (SWA) announced the Hazardous Chemical Information System (HCIS), a new database that provides information on chemicals that have been classified in accordance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The database features classification and labeling information for over 4,500 chemicals, including pictograms, and a searchable database of...

On July 29, 2016, Richard E. Engler, Senior Chemist with The Acta Group (Acta®) and B&C, was quoted in the Bloomberg BNA Daily Environment Report article, “White House Reviewing EPA Degreaser Ban.” A ban on TCE could affect a huge number of companies, according to Richard Engler, a senior chemist at the law firm Bergeson & Campbell. “This would affect any business that removes grease from metal,” Engler told Bloomberg BNA. “That could be mechanics...

The U.S. Environmental Protection Agency (EPA) proposed on July 28, 2016, revisions to the regulations governing significant new uses of chemical substances under the Toxic Substances Control Act (TSCA) with revisions to the Occupational Safety and Health Administration's (OSHA) Hazard Communications Standard (HCS) occasioned by OSHA's March 2012 final rule modifying the HCS to conform to the United Nations' (U.N.) Globally Harmonized System of Classification and Labelling of Chemicals...

Scientists Issue Letter Criticizing EDC Criteria: On July 6, 2016, a group of 15 European and U.S. researchers wrote to the European Union's (EU) Health and Food Safety Directorate, criticizing recent proposals for the identification of endocrine disrupting chemicals (EDC) under the Plant Protection Products (PPP) Regulation and the Biocidal Products Regulation (BPR). The scientists addressed two major concerns relating to the proposed criteria:...

On July 25, 2016, Inside EPA quoted Acta affiliate Bergeson & Campbell P.C.’s (B&C®) memoranda “EPA Releases First Determinations for New Chemicals under New TSCA,” on the U.S. Environmental Protection Agency’s (EPA) use of structure activity relationship (SAR) in premanufacture notice (PMN) reviews. In a July 22 memo to clients and colleagues, the law firm Bergeson & Campbell also notes that EPA appears to have used structure activity...

On June 22, 2016, Lynn L. Bergeson, President of The Acta Group (ACTA®) and Managing Partner of B&C, was quoted in Bloomberg BNA Daily Environment Report discussing the new Toxic Substances Control Act (TSCA) chemical regulatory process. Lynn Bergeson, managing partner of Bergeson & Campbell P.C., told Bloomberg BNA: “On the whole, the process seems to be efficient, but stakeholders will need to monitor the website.”...

On July 22, 2016, the U.S. Environmental Protection Agency (EPA) posted on its website the first four Section 5(a)(3) determinations for premanufacture notices (PMN) under the Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Pub. L. No. 114-182) (new TSCA). All four of the new chemicals were determined to satisfy the "not likely to present an unreasonable risk" determination at Section 5(a)(3)(C). It is notable that all...

On July 21, 2016, Michael S. Wenk, Senior Regulatory Consultant with The Acta Group (Acta®), was quoted in the Chemical Watch article Brazil maps out plans for industrial chemicals policy. Michael Wenk, senior regulatory consultant at law firm Bergeson & Campbell, said because there isn't a formal list of substances selected for the national register, “one could see” the environment ministry including parts of established national inventories, such as those...