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Tsca Inventory Articles & Analysis

70 articles found

EPA Releases Updated Version of “Working Approach” Document for New Chemicals Review

EPA Releases Updated Version of “Working Approach” Document for New Chemicals Review

Commentary It has been more than two years since EPA first published its new chemicals decision framework, and TSCA stakeholders have been eager to see the updated version. The significant time lag reflects, in part, the tremendous workload EPA is facing under new TSCA, for both new and existing chemicals. ...

ByBergeson & Campbell, P.C.


Less Than One Month until California Online Ingredients Disclosure Requirements in Effect for Designated Cleaning Products

Less Than One Month until California Online Ingredients Disclosure Requirements in Effect for Designated Cleaning Products

Chemicals identified by the federal Environmental Protection Agency’s Toxics Release Inventory as Persistent, Bioaccumulative and Toxic Chemicals that are subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (42 U.S.C. ...

ByBergeson & Campbell, P.C.


EPA Proposes TSCA CDR Revisions and Update to Small Manufacturer Definition for TSCA Section 8(a)

EPA Proposes TSCA CDR Revisions and Update to Small Manufacturer Definition for TSCA Section 8(a)

Environmental Protection Agency (EPA) released a proposed rule that would amend the Toxic Substances Control Act (TSCA) Section 8(a) Chemical Data Reporting (CDR) requirements and the TSCA Section 8(a) size standards for small manufacturers. The current CDR rule requires manufacturers (including importers) of certain chemical substances listed on the ...

ByBergeson & Campbell, P.C.


Recent Federal Developments

Recent Federal Developments

As reported in our June 25, 2018, memorandum, “EPA Publishes Final Reporting Requirements for TSCA Mercury Inventory,” the mercury rule applies to any person who manufactures (including imports) mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process (including processes traditionally not subject to the ...

ByBergeson & Campbell, P.C.


GAO Reviews EPA`s IRIS Assessment Efforts and Implementation of TSCA Reforms

GAO Reviews EPA`s IRIS Assessment Efforts and Implementation of TSCA Reforms

As reported in our February 21, 2019, memorandum, “EPA Releases Updated TSCA Inventory,” there are currently more than 40,000 active chemical substances in commerce, with more submitted to EPA for review annually. ...

ByBergeson & Campbell, P.C.


Richard E. Engler, Ph.D., Quoted in Bloomberg BNA Daily Environment Report Article “Fate of Chemical Makers’ Trade Secrets Rests With EPA”

Richard E. Engler, Ph.D., Quoted in Bloomberg BNA Daily Environment Report Article “Fate of Chemical Makers’ Trade Secrets Rests With EPA”

Environmental Protection Agency (EPA) under the New Toxic Substances Control Act (New TSCA). The 2016 update to the Toxic Substances Control Act added a new requirement that manufacturers routinely justify their need for that chemical information to be kept confidential. ...

ByBergeson & Campbell, P.C.


TSCA tips for European chemical stakeholders

TSCA tips for European chemical stakeholders

Our 26-professionals TSCA practice in Washington, D.C. has been “doing TSCA” for a very long time. ...

ByBergeson & Campbell, P.C.


EPA Eyes Nonylphenol Ethoxylates

EPA Eyes Nonylphenol Ethoxylates

Environmental Protection Agency (EPA) expanded on June 12, 2018, the list of chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) Toxics Release Inventory (TRI). The list now includes a category containing 13 nonylphenol ethoxylates (NPE). ...

ByBergeson & Campbell, P.C.


EPA Covers Confidential Chemicals

EPA Covers Confidential Chemicals

Environmental Protection Agency (EPA) issued guidance to assist companies in creating structurally descriptive chemical names for substances whose specific chemical identities are claimed confidential and for listing substances on the Toxic Substances Control Act (TSCA) Chemical Substance Inventory. Because the need to retain chemical identity confidentiality is ...

ByBergeson & Campbell, P.C.


New TSCA inspires new litigation

New TSCA inspires new litigation

When the Toxic Substances Control Act (TSCA) was legislatively 'modernised' in June 2016, no one in the legal community doubted litigation was in our collective future. ...

ByBergeson & Campbell, P.C.


Expect the EPA to be busy in 2018

Expect the EPA to be busy in 2018

Environmental Protection Agency (EPA) hit all of its new Toxic Substances Control Act (TSCA) marks in timely promulgating rules or taking other steps required by the new TSCA. TSCA developments we expect to monitor in 2018 include: Fee proposal. ...

ByActa Group


Recent Federal Developments

Recent Federal Developments

EPA Proposes Reporting Requirements For Mercury Inventory: On October 26, 2017, EPA proposed reporting requirements for the Toxic Substances Control Act (TSCA) mercury inventory. 82 Fed. Reg. 49564. Under TSCA Section 8(b)(10)(B), the mercury inventory, which includes mercury “supply, use, and trade” ...

ByBergeson & Campbell, P.C.


California Demands Disclosure of Chemicals in Cleaning Products

California Demands Disclosure of Chemicals in Cleaning Products

Under the law, “Confidential business information” means any intentionally added ingredient or combination of ingredients for which a claim has been approved by the federal Environmental Protection Agency for inclusion on the Toxic Substances Control Act (TSCA) Confidential Inventory, or for which the manufacturer or its supplier claim protection ...

ByEnhesa - Global EHS & Product Compliance Assurance


California Bill would require disclosure of cleaning product ingredients

California Bill would require disclosure of cleaning product ingredients

Environmental Protection Agency (EPA) for inclusion on the Toxic Substances Control Act (TSCA) Confidential Inventory, or for which the manufacturer or its supplier claim protection under the Uniform Trade Secrets Act. ...

ByBergeson & Campbell, P.C.


Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Paper Waste Spurs Testing of Low-Cost Carbon Fiber for Products”

Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Paper Waste Spurs Testing of Low-Cost Carbon Fiber for Products”

(B&C®), was quoted by the Bloomberg BNA Daily Environment Report discussing Toxic Substance Control Act (TSCA) regulatory concerns for carbon fiber with a lignin. Since the lignin-PAN carbon fiber under development does not yet involve the use of carbon nanofibers, Washington State University's Ahring said the product will not require clearance under ...

ByBergeson & Campbell, P.C.


Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Paper Waste Spurs Testing of Low-Cost Carbon Fiber for Products”

Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “Paper Waste Spurs Testing of Low-Cost Carbon Fiber for Products”

(B&C®), was quoted by the Bloomberg BNA Daily Environment Reportdiscussing Toxic Substance Control Act (TSCA) regulatory concerns for carbon fiber with a lignin. Since the lignin-PAN carbon fiber under development does not yet involve the use of carbon nanofibers, Washington State University's Ahring said the product will not require clearance under ...

ByBergeson & Campbell, P.C.


U.S. TSCA Reform Update: Recent Implementation Activities

U.S. TSCA Reform Update: Recent Implementation Activities

On August 11, 2017, EPA published the Final Rule in the Federal Register for the TSCA Inventory Notification. This Rule is effective immediately as of August 11, 2017. Of key importance is that manufacturers and importers will now have 180 days from this effective date to report their chemicals in commerce in the ten year period from June 21, 2006 to June 21, ...

ByUL Solutions LLC- WERCS Studio


“TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” Webinar Brings Together Industry and EPA to Talk New TSCA

“TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” Webinar Brings Together Industry and EPA to Talk New TSCA

(B&C®) is pleased to announce that the materials and recording from the “TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” webinar are now available for download. ...

ByBergeson & Campbell, P.C.


TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5

TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5

With the recent release of the 2016 Chemical Data Reporting (CDR) dataset and the initial interim list of active substances released with the June 2017 copy of the Toxic Substances Control Act (TSCA) Inventory (Inventory), the magnitude of effort that will be needed to comply with the Section 8(b)(4) Inventory notification ...

ByBergeson & Campbell, P.C.


“The New TSCA” Webinar 3:  Inventory, CDR, and CBI (Sections 8 & 14)

“The New TSCA” Webinar 3: Inventory, CDR, and CBI (Sections 8 & 14)

Three months have passed since Toxic Substances Control Act (TSCA) reform was enacted and now implementation trends are starting to take shape. Rather than waiting to see what TSCA reform's impact on your business might be, take control of your approach to "new" TSCA with the information and insight shared in the "The New TSCA: ...

ByBergeson & Campbell, P.C.

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