Christopher R. Blunck
Of Counsel
T: 202-557-3810
F: 202-557-3836
Overview
Christopher R. Blunck is an attorney with Bergeson & Campbell, P.C. (B&C®) focusing on domestic and international industrial, commercial, and consumer chemical matters. Prior to joining B&C, Mr. Blunck served as Policy Analyst and Special Assistant to the Director of the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT). Mr. Blunck has managed or participated in the development of hundreds of Toxic Substances Control Act (TSCA) and Toxics Release Inventory (TRI) Program regulations, guidance documents, and policy papers, and his decades of involvement in the regulatory development process at EPA are an invaluable asset to clients seeking to anticipate, address, and resolve regulatory compliance matters.
Representative Engagements
- Developed comments on behalf of large companies to respond to proposed TSCA regulations to ensure informed decision-making by EPA and mitigate unintended impacts on the companies and the U.S. economy more broadly.
- Assisted companies to ensure timely and concise responses to EPA TSCA audits.
- Provided counsel to chemical manufacturers, importers, processors, and distributors on regulatory requirements under TSCA.
- Prepared analyses for a Fortune 500 company and a large, multinational corporation to demonstrate product compliance with the European Union (EU) chemical control laws implementing the Stockholm Convention on Persistent Organic Pollutants.
- Provided counsel to a large, multinational company concerning the consideration of a pesticide under the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade.
- Developed and provided to chemical manufacturers and importers standard operating procedures to assist compliance with TSCA.
- Interacted with and convinced EPA on behalf of a Fortune 500 company to refund substantial TSCA fee payment.
- Assisted clients to address issues of importance contained in draft TSCA Section 5(e) Consent Orders to facilitate negotiation with EPA.
Presentations
-
Lynn L. Bergeson and Christopher R. Blunck, “Expert Focus: What Are the Implications of the US EPA’s Expected Final Rule on Persistent, Bioaccumulative and Toxic Chemicals?,” Chemical Watch, March 26, 2020.