On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming Agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” EPA states that these actions...
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On January 17, 2025, days before the end of President Biden’s term, the U.S. Environmental Protection Agency (EPA) released two new enforcement documents: (1) Expedited Settlement Agreement (ESA) Pilot Program Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (FIFRA Settlement Pilot Program or Pilot Program); and (2) Interim Consolidated Enforcement Response and Penalty Policy (Interim CERPP) for the Toxic Substances Control Act (TSCA) New and Existing Chemicals Program....
March 12, 2025
Lynn L. Bergeson, “EPA, OSHA Sign Ambiguous Memorandum of Understanding,” Chemical Processing, March 12, 2025.
The U.S. Environmental Protection Agency announced on Jan. 13, 2025, that it signed a much-anticipated 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). A closer read of the MOU leaves us wanting more than what is there....
January 28, 2025
Lynn L. Bergeson, “Chemical Regulations: 2025’s Fuzzy Forecast,” Chemical Processing, January 28, 2025.
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....
January 27, 2025
EPA Proposes Risk Management Rule to Protect Workers from Inhalation Exposure to PV29
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...
January 10, 2025
Lynn L. Bergeson, Compliance Advisor: What to Expect from EPA in 2025, Chemical Processing, January 10, 2025.
Much speculation is growing about what to expect from the U.S. Environmental Protection Agency (EPA) in 2025 under the Trump administration. Donald Trump’s presidential campaign focused on downsizing the federal government, especially the EPA. The first Trump administration tried hard to cut the agency’s workforce and funding while working to decrease regulations it viewed as burdensome. The new administration will likely follow a similar path, taking significant steps to roll back...
December 12, 2024
EPA Begins Public Consultation on Interim Framework for Advancing Consideration of Cumulative Impacts
On November 21, 2024, the U.S. Environmental Protection Agency (EPA) released a draft Interim Framework for Advancing Consideration of Cumulative Impacts (Interim Framework). 89 Fed. Reg. 92125. According to EPA, the Interim Framework provides a shared reference point for EPA programs and regions as they determine when and how to analyze and consider cumulative impacts. EPA states that Agency programs will incorporate the Interim Framework “into their processes and programs, as appropriate,...
December 6, 2024
Lynn L. Bergeson, “EPA Proposes Expanded Chemical Tracking for PFAS, Now What?,” Chemical Processing, December 6, 2024.
The number of per- and polyfluoroalkyl substances (PFAS) on the Toxics Release Inventory (TRI) list is expected to expand greatly. The U.S. Environmental Protection Agency (EPA) proposed on Oct. 8, 2024, to add 16 PFAS and 15 PFAS categories representing more than 100 individual PFAS subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA) to comply with the National Defense Authorization Act for Fiscal Year 2020...
On November 21, 2024, the U.S. Environmental Protection Agency (EPA) announced the release of the National Strategy to Prevent Plastic Pollution: Part Three of a Series on Building a Circular Economy for All. According to EPA, together with EPA’s “National Recycling Strategy” and the “National Strategy for Reducing Food Loss and Waste and Recycling Organics,” the “National Strategy to Prevent Plastic Pollution” presents opportunities for voluntary and regulatory actions by...
November 1, 2024
Lynn L. Bergeson, “EPA Extends PFAS Reporting Deadline to 2026,” Chemical Processing, November 1, 2024.
We heard a loud, collective sigh of relief when the U.S. Environmental Protection Agency (EPA) unexpectedly published a direct final rule on Sept. 5, delaying the Toxic Substances Control Act (TSCA) perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting deadline by an additional eight months. The rule delayed the deadline from May 8, 2025, to January 11, 2026. For any company reporting exclusively as an article importer and is also considered a small manufacturer, the...