All Knowledge & Insights By Date

On July 15, 2016, the California Department of Toxic Substances Control (DTSC) announced the release of its proposed regulation on children's foam-padded sleeping products containing tris(1,3-dichloro-2-propyl) phosphate (TDCPP) or tris(2-chloroethyl) phosphate (TCEP) as a Priority Product (PP) under the Safer Consumer Products Regulations (SCPR). DTSC first released information about this PP on March 13, 2014, so this proposed regulation is a major step in the SCPR process and over...

On July 15, 2016, Lynn L. Bergeson, President of The Acta Group (Acta®), was quoted in an Environmental Leader article on the impacts of the loss of a green chemistry provision from Toxic Substances Control Act (TSCA) Reform. As Lynn Bergeson, managing partner of Bergeson & Campbell writes in a blog post, the provision “called for a study of how to best incentivize sustainable chemistry research and development, as well as support ‘economic, legal and other...

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...

On July 14, 2016, Bloomberg BNA Daily Environment Report included quotes from the B&C® and Chemical Watch webinar “The New TSCA Series Webinar 2: Impacts on New Chemical Programs.” Chemical manufacturers and processors will need to give exposure and toxicity data to the EPA for it to evaluate the risks of new and existing chemicals as required by the recently amended Toxic Substances Control Act, said Charles Auer, who directed the EPA...

On July 13, 2016, the Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), in coordination with the Federal Railroad Administration (FRA), announced proposed regulations for Oil Spill Response Plans and Information Sharing for High-Hazard Flammable Trains (HHFTs). The rule would expand the comprehensive oil spill response plan requirements under the Clean Water Act (CWA) to certain HHFT trains based on the amount of crude oil being transported....

On July 12, 2016, Lynn L. Bergeson, President of The Acta Group (Acta®), was quoted in the Bloomberg BNA Daily Environment Report article “More Than 300 New Chemicals Snagged as EPA Implements Law.” Lynn Bergeson, managing partner of Bergeson & Campbell PC, told Bloomberg BNA July 11 the number of new chemicals affected by the EPA's implementation of the newly amended Toxic Substances Control Act isn't large. For an individual company,...

On July 11, 2016, Lynn L. Bergeson, President of The Acta Group (Acta®), was quoted in the IHS Chemical Week article “Responsible Care: TSCA reform and enhancing product safety.” “Chemical companies need to start paying attention to what EPA is doing and announcing—and raise concerns so they can be heard.” Lynn Bergeson, a managing partner at environmental law firm Bergeson & Campbell, agrees, adding chemical companies should “carefully monitor [EPA’s]...

In our June 29, 2016, Clients and Friends memorandum, Brazil Moves Closer to National Chemical Inventory, The Acta Group (Acta®) discussed Brazil's pending Industrial Chemicals Regulation (Regulação de Substâncias Químicas Industriais, or Regulação) predicting its imminent publication in the Brazilian Official Gazette, the Diário Oficial. On June 30, 2016, the Regulação was released for an approximately 45-day comment period. While generally...

On July 1, 2016, the ABA Journal quoted Lynn L. Bergeson, President of The Acta Group (Acta®), on the future of nanotechnology legal obligations. “The legal profession needs to be very mindful of the legal obligations that arise because of this technology,” says Lynn L. Bergeson, the managing director at Bergeson & Campbell in Washington, D.C., and chair of the Pesticides, Chemical Regulation and Right-to-Know Committee in the ABA Section of Environ­ment, Energy...

AUSTRALIA NICNAS Releases New Tool For Categorizing Polymers: The June 7, 2016, issue of the NICNAS Bulletin includes an item announcing a new tool for polymers. The National Industrial Chemicals Notification and Assessment Scheme (NICNAS) invites stakeholders to try the new polymer categorization tool, which NICNAS developed to help users understand how the health and environment hazards of polymers would be...