This week, I sat down with Dr. Richard Engler, our Director of Chemistry, to discuss Confidential Business Information (CBI). CBI is both a term of art under the Toxic Substances Control Act (TSCA) and can be understood broadly to be anything from trade secrets to you know, the secret sauce of a chemical formulation that makes a product profitable. In our conversation, we focused on how this concept of CBI functions under TSCA and how businesses need to handle CBI during the EPA’s chemical review process.
Rich is the perfect person to discuss the concept of CBI. Rich is 17-year veteran of the U.S. Environmental Protection Agency (EPA). He has participated in thousands of Toxic Substances Control Act (TSCA) substance reviews at EPA, and knows the ins-and-outs of how CBI should be handled.
Our conversation touches upon some of the most important legal and business considerations when dealing with CBI and the EPA: how the EPA exactly defines CBI, where problems can arise, and how to avoid these through careful preparation and planning.
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