All Knowledge & Insights By Date

In April 2024, the US Environmental Protection Agency (EPA) opened an enormous can of worms for entities even remotely association with the generation, transport, use or disposal of two legacy per- and polyfluoroalkyl substances (PFAS): perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). In designating the PFAS as “hazardous substances” under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the EPA greenlit the initiation of...

It’s been almost nine years since Toxic Substances Control Act (TSCA) stakeholders celebrated President Obama’s enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) on June 22, 2016. Because the road to amending TSCA was long (almost a decade), contentious and complicated, stakeholders may have been more relieved that the process was finally over than interested in the fine print....

It has been almost nine years since Toxic Substances Control Act (TSCA) stakeholders celebrated President Obama’s enactment on June 22, 2016, of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). Because the road to amending TSCA was long (almost a decade), contentious, and complicated, stakeholders were perhaps more relieved that the process was finally over than inclined to focus on the fine print. This article discusses mid-course corrections that are desperately...

On January 16, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested public comment on the draft scope of the risk evaluation to be conducted under the Toxic Substances Control Act (TSCA) for vinyl chloride. 90 Fed. Reg. 4738. EPA notes that under TSCA, the scope documents must include the conditions of use (COU), hazards, exposures, and the potentially exposed or susceptible subpopulations (PESS) that EPA expects to consider in conducting its risk...

For all the reasons you might imagine, 2025 is an especially challenging year to speculate on what to expect regarding global industrial, agricultural and biocidal chemical regulatory and policy initiatives. We give it our best shot in this article....

On January 14, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to address the unreasonable risk of injury to human health presented by Color Index (C.I.) Pigment Violet 29 (PV29) under its conditions of use (COU) as documented in EPA’s January 2021 risk evaluation and September 2022 revised risk determination. 90 Fed. Reg. 3107. The proposed rule states that the Toxic Substances Control Act (TSCA) requires that EPA address by rule any unreasonable risk of injury to...

The European Chemicals Agency (ECHA) announced on January 21, 2025, that it added five chemicals to the Candidate List of substances of very high concern (SVHC) and updated one entry: Substance NameReason for InclusionExamples of Uses6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acidToxic for reproduction (Article 57(c))Lubricants, greases, release products, and metal working fluidsO,O,O-triphenyl...

On January 14, 2025, the U.S. Environmental Protection Agency (EPA) released the final risk evaluation for diisononyl phthalate (DINP) conducted under the Toxic Substances Control Act (TSCA). EPA states that it has determined that DINP presents an unreasonable risk of injury to human health because workers could be exposed to high concentrations of DINP in mist when spraying adhesive, sealant, paint, and coating products that contain DINP. According to EPA, DINP can cause developmental toxicity...

The U.S. Environmental Protection Agency (EPA) announced on January 13, 2025, that it signed a long-awaited memorandum of understanding (MOU) with the Occupational Safety and Health Administration (OSHA) formalizing coordination on EPA’s work to assess and manage existing chemicals under Section 6 of the Toxic Substances Control Act (TSCA). According to EPA’s press release, “EPA and OSHA anticipate that better coordination under this MOU will result in improved workplace health and safety...

The U.S. Environmental Protection Agency (EPA) released final risk management rules under the Toxic Substances Control Act (TSCA) for trichloroethylene (TCE) and perchloroethylene (PCE) on December 9, 2024, and for carbon tetrachloride (CTC) on December 11, 2024. EPA states that all uses of TCE will be banned over time, with “the vast majority of identified risks eliminated within one year,” and safer alternatives readily available for the majority of uses. The PCE rule will ban manufacture,...