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Tsca Requirement Articles & Analysis

69 articles found

TSCA Requirements for Importing Chemicals

TSCA Requirements for Importing Chemicals

What are TSCA Import Certification Requirements? It is mandatory for importers of any chemical substance, chemical mixtures, or articles that contain a chemical substance to follow the Toxic Substances Control Act (TSCA) to be a part of the U. ...

ByEnventure Engineering LLC - ComplianceXL


Final List of High-Priority Chemicals Will Be Next to Undergo Risk Evaluation under TSCA

Final List of High-Priority Chemicals Will Be Next to Undergo Risk Evaluation under TSCA

These chemicals will be the next 20 chemicals to undergo risk evaluation under the amended Toxic Substances Control Act (TSCA). According to EPA, issuing the final list of high-priority chemicals for risk evaluation “represents the final step in the prioritization process outlined in TSCA and marks another major TSCA milestone for EPA in ...

ByBergeson & Campbell, P.C.


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

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

Critics of this approach insist that EPA is putting workers at risk because some workers are not properly informed, trained, or equipped, in violation of OSHA requirements. Those critics do not explain how a duplicative TSCA requirement would remedy that situation. EPA states that it evaluates whether standard hazard communication and PPE are ...

ByBergeson & Campbell, P.C.


EPA Announces Final SNUR for Asbestos Will “Close Loophole and Protect Consumers”

EPA Announces Final SNUR for Asbestos Will “Close Loophole and Protect Consumers”

” The restricted significant new uses of asbestos (including as part of an article) are manufacturing (including importing) or processing for uses that are neither ongoing nor already prohibited under TSCA. Persons subject to the SNUR may not undertake any of these activities; they are required to notify EPA at least 90 days before commencing any ...

ByBergeson & Campbell, P.C.


Recent Federal Developments

Recent Federal Developments

More information is available online. EPA Proposes TSCA CDR Revisions And Update To Small Manufacturer Definition For TSCA Section 8(a): On April 12, 2019, EPA released a proposed rule that would amend the TSCA Section 8(a) Chemical Data Reporting (CDR) requirements and the TSCA Section 8(a) size standards for ...

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 ...

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

EPA’s Implementation of New TSCA GAO found that EPA has demonstrated progress in implementing TSCA by responding to TSCA’s statutory deadlines through the end of fiscal year 2018, including promulgating rules, developing guidance, and releasing reports. ...

ByBergeson & Campbell, P.C.


Sheryl Lindros Dolan Presents “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the SCHC Spring Meeting

Sheryl Lindros Dolan Presents “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the SCHC Spring Meeting

(B&C®), presented “Protecting Trade Secrets Around the World Part 1: Comparing CBI Requirements under New TSCA and OSHA HCS 2012” at the Society for Chemical Hazard Communication (SCHC) Spring Meeting. ...

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.


EPA Covers Confidential Chemicals

EPA Covers Confidential Chemicals

Background The “Guidance for Creating Generic Names for Confidential Chemical Substance Identity Reporting under the Toxic Substances Control Act,” was developed in response to the new TSCA Section 14(c)(4) requirement that the EPA “develop guidance regarding – (A) the determination of structurally descriptive generic names, in the case ...

ByBergeson & Campbell, P.C.


TSCA at 2: An Update on Implementation and Hot Topics

TSCA at 2: An Update on Implementation and Hot Topics

Environmental Protection Agency (EPA) has implemented a muscular regulatory program expressing Congress’ intent for a new and improved Toxic Substances Control Act (TSCA). The new TSCA framework required significant work and fundamental shifts in regulatory requirements and conceptual approach, but EPA has hit all of its ...

ByBergeson & Campbell, P.C.


Citizens Challenge EPA - Case study

Citizens Challenge EPA - Case study

A petition filed under Section 21 of the Toxic Substances Control Act (TSCA) was one of the first actions reviewed by a federal district court since TSCA was substantially rewritten in June 2016.The rulings described below pose interesting and potentially formidable challenges for TSCA stakeholders. Background TSCA Section 21 ...

ByBergeson & Campbell, P.C.


Citizens challenge EPA

Citizens challenge EPA

A petition filed under Section 21 of the Toxic Substances Control Act (TSCA) was one of the first actions reviewed by a federal district court since TSCA was substantially rewritten in June 2016.The rulings described below pose interesting and potentially formidable challenges for TSCA stakeholders. Background TSCA Section 21 ...

ByActa Group


James V. Aidala Quoted By Bloomberg BNA Daily Environment Report Regarding EPA’s New Science Advisory Committee on Chemicals

James V. Aidala Quoted By Bloomberg BNA Daily Environment Report Regarding EPA’s New Science Advisory Committee on Chemicals

Getting and following a science advisory committee's recommendations, however, doesn't guarantee all parties will agree with the EPA's final decision nor that EPA will make the right decision, Aidala added. […] Amended TSCA requires the agency to conduct more risk-based analyses than the original law required, and it strictly limits the ...

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.


EPA Proposes TSCA User Fees - Case study

EPA Proposes TSCA User Fees - Case study

Beginning in fiscal year 2019 (October 1, 2018), the EPA is required to adjust fees every three years to reflect inflation and ensure that fees account for 25% of the EPA’s costs in administering TSCA Sections 4, 5, 6 and 14. ...

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


Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environment Report Article “Citizens Petitions, Lawsuits on Chemical Rules Likely to Grow”

Lynn L. Bergeson Quoted in Bloomberg BNA Daily Environment Report Article “Citizens Petitions, Lawsuits on Chemical Rules Likely to Grow”

Bergeson, Estreicher, and Gotting all cited a lawsuit that attracted attention this year after a federal district court ruled late December that the EPA erred in its interpretation of amended TSCA's requirements for citizens’ petitions. The case, Food & Water Watch v. ...

ByBergeson & Campbell, P.C.


EPA: Mercury merits attention

EPA: Mercury merits attention

The 2016 amendments to the Toxic Substances Control Act (TSCA) call for the EPA to establish periodic mercury reporting requirements for manufacturers of mercury or mercury-added products or those that use mercury in a manufacturing process to assist in developing an inventory of mercury and other recommended actions. ...

ByActa Group


Chemical Watch Quotes the TSCA New Chemicals Coalition in “Industry group: US EPA should cede workplace hazard regulation to Osha”

Chemical Watch Quotes the TSCA New Chemicals Coalition in “Industry group: US EPA should cede workplace hazard regulation to Osha”

On December 15, 2017, Chemical Watch featured comments by the TSCA New Chemicals Coalition (NCC) on the U.S. Environmental Protection Agency’s (EPA) new chemical evaluation policy. ...

ByBergeson & Campbell, P.C.

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