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Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to share that Lynn L. Bergeson will present during the American Bar Association (ABA) Section of Environment, Energy, and Resources’ (SEER) Pesticides and Chemicals Committee’s “Careers in Chemicals” webinar on October 20, 2023, at 12:00 p.m. (EDT). This event will feature a panel of experienced attorneys who will discuss their legal careers, why they focus their practice on chemical...
October 16, 2023
Lynn L. Bergeson, “EPA Issues Final Rule on TSCA PFAS Reporting Requirements,” Chemical Processing, October 16, 2023.
On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released its long-overdue final rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The rule requires reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). As discussed in this article, the final rule is not what many of us expected nor wanted....
October 13, 2023
HSE Begins Public Consultation on Draft Recommendation to Add DIHxP to UK REACH Authorization List
The United Kingdom (UK) Health and Safety Executive (HSE) began a public consultation on September 18, 2023, on its draft recommendation for 2023 to include diisohexyl phthalate (DIHxP) on the authorization list (Annex 14 of UK REACH). According to HSE’s draft background document, the European Chemicals Agency (ECHA) prioritized DIHxP and included DIHxP in its April 12, 2023, recommendation for the inclusion of substances in the European Union (EU) Registration, Evaluation, Authorisation and...
October 12, 2023
FDA Seeks Comment on Cosmetics Direct and Forms Regarding Registration of Cosmetic Product Facility and Cosmetic Product Listing
On September 15, 2023, the U.S. Food and Drug Administration (FDA) announced that it is seeking comment on its newly developed draft electronic submission portal (Cosmetics Direct) and paper forms (Forms FDA 5066 and 5067). The submission portal and paper forms are part of FDA’s implementation of the new registration and listing requirements mandated by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). FDA has provided screenshots of the draft electronic system, draft Form FDA...
October 11, 2023
Lynn L. Bergeson Quoted in Bloomberg Law Article “EPA’s Final PFAS Data Rule Seen as Ripe for Industry Challenges”
On October 10, 2023, comments by Lynn L. Bergeson were featured in Bloomberg Law's article on the U.S. Environmental Protection Agency's (EPA) decision to require companies to report extensive information about per- and polyfluoroalkyl substances (PFAS) in their merchandise. Not every attorney thinks the rule could be legally vulnerable.The regulatory burden, especially on small business entities, is high, and the scope of the reporting obligation is “insanely broad,” said...
On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released a long-overdue final rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) regarding reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). As discussed below, the final rule is not what many of us expected, nor wanted. EPA states that the reporting rule is a statutory requirement under the fiscal year (FY) 2020 National Defense Authorization Act (NDAA) that requires...
September 29, 2023
Karin F. Baron, MSPH, and Richard E. Engler, Ph.D., to Speak at SCHC’s Annual Meeting
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Karin F. Baron, MSPH, Director of Hazard Communication and International Registration Strategy, and Richard E. Engler, Ph.D., Director of Chemistry, will present the full-day Regulatory Jurisdiction Workshop on October 2, 2023, an intermediate course where participants will gain a clearer understanding of the Toxic Substances Control Act (TSCA), the Federal...
September 28, 2023
EPA and DOJ Claim eBay Unlawfully Sold Pesticides, Banned Chemical Products, and Devices That Defeat Pollution Controls on Motor Vehicles
The U.S. Environmental Protection Agency (EPA) announced on September 27, 2023, that the U.S. Department of Justice (DOJ), on behalf of EPA, filed a complaint against eBay Inc. (eBay) “for unlawfully selling, offering for sale, causing the sale of, and distributing hundreds of thousands of products” in violation of the Clean Air Act (CAA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Toxic Substances Control Act (TSCA). According to EPA, the complaint seeks a...
September 26, 2023
IBA Agriculture and Food Section Shares “Responsible Land-Based Investments in Agriculture: Latin America” Recording and Announces IBA Annual Conference Sessions
The International Bar Association (IBA) Agriculture and Food Section (AFS) is sponsoring two sessions at the IBA Annual Conference Paris 2023, covering the increase in antimicrobial resistance (AMR) as it impacts global food security and ways to protect biodiversity through legal instruments. Antimicrobial resistance regulation in the context of one health: how legislation can help reduce AMR, Tuesday, October 31, 2023, 11:15 a.m. – 12:30 p.m. (CET), AFS is lead...
The U.S. Consumer Product Safety Commission (CPSC) published a request for information (RFI) on per- and polyfluoroalkyl substances (PFAS) used in commerce or potentially used in consumer products, potential exposures associated with the use of PFAS in consumer products, and potential human health effects associated with exposures to PFAS from their use in consumer products. 88 Fed. Reg. 64890. CPSC also announced the availability of a contractor report with a focus on PFAS that are potentially...