Bergeson & Campbell, P.C.

Metals Practice Services

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The wealth of B&C’s experience working at and with numerous state, federal, and international agencies positions us to advocate effectively for our clients before problems arise and to mitigate issues after the fact. We have worked for years with staff at EPA, OSHA, the U.S. Department of State, state regulatory agencies such as California’s Office of Environmental Health Hazard Assessment (OEHHA), and other governmental venues.

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Areas in which we advise clients include the following:

  • Legislative Policy –
    • Advise clients on impacts of proposed legislative actions or policies, including the U.S, Securities and Exchange Commission’s (SEC) conflict minerals regulations, TSCA reform actions, and others
    • Provide leadership role for metals industry in an ad hoc coalition of chemical trade associations in TSCA reform debate
  • U.S. Chemical Control and Assessment Actions –
    • Active participation in Science Advisory Board (SAB) reviews, and participation in workshops, peer review efforts, and expert consultations
    • Provide context of ongoing regulatory actions by EPA in chemical control programs and potential impact to the metals industry and develop strategies to minimize burden or unintended consequences, including
      • Scheduled assessments of numerous metals under the Integrated Risk Information System (IRIS) process
      • Reporting of metals and metal byproducts under CDR
      • Inclusion of metal substances in EPA’s TSCA Work Plan efforts
      • Prioritization of chemicals in commerce
  • Classification and Labeling Requirements –
    • Provide educational outreach to metals community on impacts of new classification and labeling requirements in the U.S. and other regions
    • Remain engaged in ongoing research and modeling developments that better address the physical and chemical characteristics of metals within a classification context
  • Research –
    • Conduct and publish research focused on providing more scientifically robust approaches to regulate and manage metal substances
  • International Treaties and Programs –
    • Lead industry efforts in providing input to U.S. delegates to International Maritime Organization (IMO) and United Nations Environment Programme (UNEP) on mercury, sustainable development, and other international activities impacting metals
    • Meet with U.S. State, Commerce, and Transportation Departments to assist the U.S. in developing a position on the Strategic Approach to International Chemicals Management (SAICM) and mercury-related issues
  • Coordination with Key Government Groups on Sustainability Issues –
    • Monitor and report on developments with respect to the international “3Rs” initiative (reduce, recycle, reuse), Health Canada Exposure Model, draft Canadian Ecological Categorization of Organometallics, and UNEP Executive Director’s draft report
    • Establish and maintain connections along the value chain in conjunction with key government organizations to address issues related to procurement processes and sustainability goals for those government groups
  • Training –
    • Coordinate and host seminars for metals industry