Archives

December 12, 2025

Lynn L. Bergeson, Hallelujah, EPA Proposes to Narrow Scope of TSCA Section 8(a)(7) PFAS Reporting Rule, Chemical Processing, December 10, 2025.

On Nov. 13, 2025, the U.S. Environmental Protection Agency (EPA) proposed revisions (90 Fed. Reg. 50923) to the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). This column summarizes the proposal and the reasons for it....
December 8, 2025

EPA Begins Public Comment Period on Updated Draft Risk Calculation Memorandum for Formaldehyde

On December 3, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited public comment on an Updated Draft Risk Calculation Memorandum (Draft Memorandum) to inform a revised draft risk evaluation for formaldehyde under the Toxic Substances Control Act (TSCA). 90 Fed. Reg. 55726. EPA states that after further consideration of comments raised during the scientific peer review process, it is reconsidering the use of certain hazard values in the formaldehyde...
November 25, 2025

EPA Publishes Default Values Used in New Chemical Risk Assessments under TSCA

On November 24, 2025, the U.S. Environmental Protection Agency (EPA) released the key default values that it uses in its risk assessments of new chemicals under the Toxic Substances Control Act (TSCA). EPA is making the assumptions available on its website in the New Chemicals Division Reference Library. EPA states that it expects the publication of the default values “to improve efficiency, reducing the likelihood that submissions need to be reworked or resubmitted.” According to EPA,...
November 20, 2025

EPA Preliminarily Determines that 1,2-Dichloroethane Poses Unreasonable Risk to Human Health and the Environment

On November 19, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested comment on a draft risk evaluation under the Toxic Substances Control Act (TSCA) for 1,2-dichloroethane (Chemical Abstracts Service Registry Number® (CAS RN®) 107-06-2, also known as ethylene dichloride or EDC). 90 Fed. Reg. 52054. EPA notes that the purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health...
November 13, 2025

EPA Proposes to Narrow Scope of TSCA Section 8(a)(7) PFAS Reporting Rule; Exemptions Would Include De Minimis Amounts, Imported Articles

On November 13, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to amend the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). 90 Fed. Reg. 50923. As reported in our October 3, 2023, memorandum, the final rule requires manufacturers (including importers) of PFAS and PFAS-containing articles in any year since 2011 through 2022 to report information...
October 31, 2025

Senate Subcommittee Examines Beneficial Use and Regulation of Chemicals

On October 23, 2025, the Senate Environment and Public Works Subcommittee on Chemical Safety, Waste Management, Environmental Justice, and Regulatory Oversight held a hearing on “Examining the Beneficial Use and Regulation of Chemicals.” The Subcommittee heard from the following witnesses: Peter Huntsman, President and Chief Executive Officer (CEO), Huntsman Corporation (written testimony); Dr. Gwen Gross, Senior Technical Fellow, The Boeing Company (written testimony); and Dr. Tracey...
October 14, 2025

Lynn L. Bergeson, “Defining Risk: EPA Seeks Major TSCA Chemical Evaluation Reforms,” Chemical Processing, October 13, 2025.

On Sept. 23, 2025, the U.S. Environmental Protection Agency (EPA) proposed highly anticipated amendments to the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA). When conducting a TSCA existing chemical risk evaluation, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or non-risk factors under the conditions of use (COU). As...
September 26, 2025

Phthalate Risk Evaluation under TSCA and the Potential Impacts to the Plastics Industry, October 30, 2025, 11:00 a.m. – 12:00 p.m. (EDT), via webinar

Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) are pleased to present “Phthalate Risk Evaluation under TSCA and the Potential Impacts to the Plastics Industry,” a complimentary webinar that explores the background and current status of the U.S. Environmental Protection Agency’s (EPA) precedent-setting review of seven phthalates under Toxic Substances Control Act (TSCA) Section 6. By integrating its cumulative risk...
September 24, 2025

EPA Proposes to Amend TSCA Risk Evaluation Framework

On September 23, 2025, the U.S. Environmental Protection Agency (EPA) proposed highly anticipated amendments to the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA). 90 Fed. Reg. 45690. When conducting an existing chemical risk evaluation under TSCA, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or nonrisk factors, including...
July 16, 2025

Lynn L. Bergeson, “Leveraging Chemical Data More Efficiently,” PCB007 Magazine, July 2025.

Some truths transcend politics, one being that chemical data holds enduring value and is becoming increasingly essential. In the United States, regardless of which party federally controls the levers of power, it’s clear that chemical manufacturers and their customers must develop and curate robust data portfolios for their chemical inventories. The commercial imperatives driving this are undeniable and gaining traction....