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ergeson & Campbell, P.C. (B&C), B&C Consortia Management, L.L.C. (BCCM), and The Acta Group (Acta) are pleased to announce that BCCM is a proud sponsor of the 2nd Safer Products Summit, which will be held on April 2-4, 2013, in San Francisco, California. The conference will bring together policy makers, leading consumer brands, and green chemistry experts to lay out the framework for complying with California's Safer Consumer Products Regulations....
Rosemarie Kelley, Director, Waste and Chemical Enforcement Division, U.S. Environmental Protection Agency's (EPA) Office of Enforcement and Compliance Assurance, announced during a recent industry meeting that one of EPA's enforcement priorities will be to look at how manufacturers are naming and listing fractions of existing chemicals for Toxic Substances Control Act (TSCA) Inventory purposes. Kelley stated that fractions or "slices" of existing substances could be new chemical substances for...
Reporting on “the proposed significant new use rules (SNURs) for some 37 chemicals including more than a dozen nanomaterials,” Inside EPA included commentary issued by Bergeson & Campbell, P.C.: “In Feb. 26 commentary on the new proposal, the law firm Bergeson & Campbell, P.C. notes that one-third of the substances were subject to premanufacture notice reviews prior to 2010 and that for some materials that review period was more than a decade ago. The commentary...
March 8, 2013
Materials from Successful B&C and CPDA Workshop to Explore Agricultural Product Challenges with GHS
On February 28, 2013, the Council of Producers & Distributors of Agrotechnology (CPDA) and Bergeson & Campbell, P.C. (B&C) jointly sponsored a workshop on Global Harmonization System (GHS) labeling requirements for agricultural chemicals. The workshop featured speakers from the U.S. Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Department of Transportation (DOT), and Lynn L. Bergeson, and explored OSHA's final rule modifying its...
On March 5, 2013, the U.S. Environmental Protection Agency (EPA) published in the Federal Register an important final rule certifying additional fuel pathways that meet the biomass-based diesel, advanced biofuel, or cellulosic biofuel lifecycle greenhouse gas (GHG) reduction requirements under the Renewable Fuel Standard (RFS) Program. The final rule describes EPA's evaluation of advanced biofuels produced from camelina (Camelina sativa) oil and energy cane plants,...
On February 25, 2013, the U.S. Environmental Protection Agency (EPA) published proposed significant new use rules (SNUR) under the Toxic Substances Control Act (TSCA) for 37 chemical substances that were the subject of premanufacture notices (PMN). In addition, 17 of the chemical substances are subject to TSCA Section 5(e) consent orders issued by EPA. If issued in final, the SNURs would require persons who intend to manufacture, import, or process the chemical substances for an activity that is...
February 25, 2013
Court of Appeals Issues Landmark Ruling Vacating Biological Opinion Concerning Effects of Three Pesticides on Salmon Species
On February 21, 2013, a three judge panel of the Fourth Circuit Court of Appeals issued a unanimous landmark decision in Dow Agrosciences v. National Marine Fisheries Service setting aside a Biological Opinion (BiOp) prepared by the National Marine Fisheries Service (NMFS) that found that use of the pesticides chlorpyrifos, diazinon, and malathion could jeopardize the viability of certain species of salmon and their habitat. The decision will have significant implications for...
February 21, 2013
EPA Issues ICR Concerning Health Effects Research Requirements for Manufacturers of Fuels and Fuel Additives
The U.S. Environmental Protection Agency (EPA) published in the February 20, 2013, Federal Register a notice announcing its intent to extend an Information Collection Request (ICR) concerning "Registration of Fuels and Fuel Additives -- Health-Effects Research Requirements for Manufacturers." Manufacturers (including importers) of fuels and additives designated by EPA, including motor-vehicle gasoline, motor-vehicle diesel fuel, and additives for those fuels, are required to...
February 15, 2013
EPA Studies, California Rules May Guide “Risk” Level Absent TSCA Reform
The February 15, 2013, issue of Inside EPA quoted Lynn L. Bergeson extensively. “In lieu of reform legislation clearing Congress, Lynn Bergeson, a TSCA attorney and owner of law firm Bergeson & Campbell, told a recent legal conference that industry lawyers should be closely watching the agency’s first batch of five draft risk assessments, released last month, given that they could serve as an early indication of how EPA’s toxics office will...
February 14, 2013
Change of Leadership on Senate Environment and Public Works Subcommittee Unlikely to Affect TSCA Reform Efforts
The February 14, 2013, issue of Bloomberg BNA Daily Environment Report notes Lynn L. Bergeson “anticipates Lautenberg’s move will not affect the TSCA-reform debate,” in the article “Lautenberg Stepping Down as Chairman Of Panel With TSCA, Superfund Jurisdiction.” “Lautenberg is still a champion of TSCA reform, and will no doubt continue to push for reform. Whether that happens any time soon continues to be doubtful given the lack of...