All Knowledge & Insights By Date

The U.S. Environmental Protection Agency (EPA) announced on January 9, 2024, the automatic addition of seven per- and polyfluoroalkyl substances (PFAS) to the list of chemicals covered by the Toxics Release Inventory (TRI). For TRI Reporting Year 2024 (reporting forms due by July 1, 2025), reporting is required for these seven additional PFAS, bringing the total PFAS subject to TRI reporting to 196. The Fiscal Year (FY) 2020 National Defense Authorization Act (NDAA) includes a...

The Law Library of Congress published a November 2023 report entitled Selected Issues in Biotechnology Regulation: Australia, Belgium, Brazil, Canada, China, England, European Union, Germany, India, Japan, Mexico, New Zealand, Singapore, South Africa, South Korea, Taiwan that provides an overview of the main statutes and policies governing selected issues on the development of biotechnology products, particularly those derived from genetically modified organisms (GMO) and genetic engineering....

TSCA/FIFRA/TRI EPA Publishes Final SNURs On Certain Chemical Substances: The U.S. Environmental Protection Agency (EPA) published final significant new use rules (SNUR) on December 18, 2023, for certain chemical substances that were the subject of premanufacture notices (PMN) and are also subject to an Order issued by EPA pursuant to the Toxic Substances Control Act (TSCA). 88 Fed. Reg. 87346. The SNURs require persons who intend to manufacture (defined by statute to include import) or...

The New Year is upon us, and 2024 is shaping up to be consequential on a global scale.  First, let’s look at U.S. policy and regulatory developments. In this election year, competing priorities will dominate U.S. Environmental Protection Agency (EPA) actions. The agency will seek to complete as many actions as possible while tempering its expectations to avoid any significant pre-election missteps. While there is no consensus on whether the Biden administration’s commitment to policy...

On January 4, 2024, the Washington Department of Ecology (WDOE) submitted a petition to the U.S. Environmental Protection Agency (EPA) under Section 21 of the Toxic Substances Control Act (TSCA) seeking a rulemaking to eliminate the current allowances for polychlorinated biphenyls (PCB) in consumer products. WDOE states that its research found that when PCBs are found in consumer products, “they are byproducts known to be associated with pigments, paints, or inks used in the manufacturing...

On January 11, 2024, the U.S. Environmental Protection Agency (EPA) issued a final significant new use rule (SNUR) to prevent companies from starting or resuming the manufacture (including import) or processing of 329 per- and polyfluoroalkyl substances (PFAS) that are designated as inactive on the Toxic Substances Control Act (TSCA) Chemical Substance Inventory. 89 Fed. Reg. 1822. The final rule notes that persons subject to the final SNUR are required to notify EPA at least...

On January 11, 2024, Lynn L. Bergeson was quoted by ICIS in the article “US on track to restrict VCM, ACN, aniline under TSCA.” Under President Joe Biden, the EPA has taken a whole chemical approach to determine whether a substance poses an unreasonable risk. Under such an approach, the EPA is expected to find that VCM, ACN, aniline and the other two chemicals pose unreasonable risks, said Lynn Bergeson, managing partner at Bergeson & Campbell, a law firm that...

The Minnesota Pollution Control Agency (MPCA) has published a request for comments (RFC) on planned new rules governing currently unavoidable use (CUU) determinations for products containing per- and polyfluoroalkyl substances (PFAS). According to the RFC, the main purpose of the rulemaking is to establish criteria and processes through which MPCA will make decisions on what uses of intentionally added PFAS will qualify as CUUs in products sold, offered for sale, or distributed in Minnesota. Any...

B&C® Consortia Management, L.L.C. (BCCM) is seeking a Consortium Manager (Manager) to provide operational, administrative, financial, and communication strategy and support to assigned BCCM consortia clients. The Manager reports to the BCCM Senior Manager. This position will be directed from our Washington, D.C., office with flexible telework arrangements available., including full time remote option. Overview of Requirements The successful candidate will be an experienced project manager...

Download transcript. This week, I welcomed back to the studio Karin F. Baron, Director of Hazard Communication and International Registration Strategy at B&C and our consulting affiliate, The Acta Group. Karin and I discuss an old but evolving concept in FDA circles called GRAS — Generally Recognized as Safe. As listeners may know, “food additives” require pre-market approval by FDA. Substances “generally recognized” as safe under the conditions of a substance’s intended use...