Richard E. Engler, Ph.D.
Director of Chemistry
Richard E. Engler, Ph.D. is Director of Chemistry with The Acta Group (Acta®). Dr. Engler is a 17-year veteran of the U.S. Environmental Protection Agency (EPA) and is one of the most widely recognized experts in the field of green chemistry, having served as senior staff scientist in EPA’s Office of Pollution Prevention and Toxics (OPPT) and leader of EPA’s Green Chemistry Program. He has participated in thousands of Toxic Substances Control Act (TSCA) substance reviews at EPA, as well as pre-notice and post-review meetings with submitters to resolve complex or difficult cases, and he draws upon this invaluable experience to assist B&C clients as they develop and commercialize novel chemistries.
- Assisted a small start-up company with developing a research and development (R&D) plan for its customers’ scale-up testing to document compliance with the TSCA R&D exemption.
- Assisted a chemical importer to evaluate whether the imported products are taxable under the Superfund Tax and, if so, to calculate the tax rate.
- Assisted a Fortune 50 company with business-critical new chemical notice and coordinated closely with EPA to achieve timely success.
- Prepared an Optional P2 Statement for a premanufacture notice (PMN) submitted by a leading global specialty chemical company that led to a determination of reduced relative risk and no Section 5 regulatory action on the PMN substance.
- Responded to concerns raised during review of a PMN submitted to reduce a risk-based, up-front ban to a non-risk-based Significant New Use Rule (SNUR).
- Prepared comments on an existing chemical SNUR to describe accurately ongoing uses to protect a Fortune 500 business’s critical product lines and protect confidential business information.
- Assisted a small startup biobased chemical company with determining which of its intermediates and byproducts are reportable under TSCA.
- Assisted a leading U.S. additive producer with a substance identity profile (SIP) and sameness reviews for Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) registrations.
- Prepared a regulatory analysis to demonstrate compliance with TSCA Chemical Data Reporting (CDR) regulations and to avoid a threatened lawsuit against a Fortune 500 company.
- Assisted a global chemical company with preparation for an EPA TSCA audit and attended the site visit by EPA inspectors; addressed the inspector’s questions in the moment, avoiding additional follow-on questions by EPA.
- Assisted a small company to respond to an EPA TSCA audit; ensured that responses were within the scope of the audit, avoiding additional data gathering.
Professional and Community Involvement
- Member, American Chemical Society, 1986 – present
- ACS GCI/NSF Standard 355 – Joint Committee for Greener Chemicals, Products and Processes Information Standard (vice chair, subgroup chair, voting member), 2009-2011
- Green Chemistry and Engineering Conference Organizing Committee, 2002-2010, 2013
- Office of Pollution Prevention and Toxics, Diversity Action Plan Committee, 1999-2001
Articles and Writings
Richard E. Engler, Ph.D., and Todd J. Stedeford, Ph.D., DABT®, ERT, ATS, “What are the key elements and likely impact of the EPA’s proposed rule for methylene chloride?,” Chemical Watch, June 21, 2023.
Richard Engler, Ph.D., “Pre-market Approval of Chemical Substances: How New Chemical Products Are Regulated,” in How to Commercialize Chemical Technologies for a Sustainable Future, John Wiley & Sons, Ltd. (2021).
Lynn L. Bergeson, Christopher Blunck, and Richard Engler, Ph.D., co-authors, “Pesticides, Chemical Regulation, and Right-to-Know 2020 Annual Report,” in The Year in Review 2020: Environment, Energy, and Resources Law, American Bar Association (2021).
Lynn L. Bergeson, Charles Auer, Richard Engler, Ph.D., and Kathleen Roberts, co-authors, “Pesticides, Chemical Regulation, and Right-to-Know 2019 Annual Report,“ in The Year in Review 2019: Environment, Energy, and Resources Law, American Bar Association (2020).
“WEBINAR – Articles under TSCA,” Bergeson & Campbell, P.C., (December 14, 2022).
“TSCA Section 18 — Preemption,” HCPA XPAND2022, (December 6, 2022).
“Biobased Chemicals under TSCA,” HCPA XPAND2022, (December 5, 2022).
“Living in a Circular World: The Challenges of Complying with TSCA,” Product Sustainability Summit USA 2022, (November 16, 2022).