TSCA Reform: Eight Years Later — Panel 4: Shaping the Agenda, Section 21 Citizens’ Petitions and Other Mechanisms Influencing Priority Setting

On June 26, 2024, B&C, along with the Environmental Law Institute and the George Washington University Milken Institute of Public Health, sponsored the all-day virtual conference, TSCA Reform — Eight Years Later. The quality of the discussion, the caliber of the participants, and the timeliness of the content motivated us to repurpose the substantive sessions. B&C and ELI are pleased to co-sponsor this episode of All Things Chemical® to enable our podcast audience to listen to these sessions.

Lynn L. Bergeson moderated Panel 4: Shaping the Agenda: Section 21 Citizens’ Petitions and Other Mechanisms Influencing Priority Setting. The panelists included Ryan J. Carra, Ph.D., Principal, Beveridge & Diamond, P.C.; Michael Connett, Partner, Siri & Glimstad LLP; Thomas Groeneveld, Senior Advisor, Existing Chemicals Risk Management Division, EPA; and Robert M. Sussman, Principal, Sussman & Associates. Citizens’ petitions under TSCA Section 21 are increasingly playing a prominent and evolving role in influencing EPA’s policy and regulatory priorities. Other mechanisms are also being used to revisit EPA’s priorities. The panel discussed the utility of these mechanisms, how they are impacting EPA’s regulatory agenda, and other opportunities for citizen engagement. The panel commented on the implications of EPA’s decision to grant a TSCA Section 21 petition to address only a single condition of use (COU) of the chemical N-(1,3-Dimethylbutyl)-N′-phenyl-p-phenylenediamine (6PPD). More information on the petition to address 6PPD in tires is available in our November 3, 2023, blog item.

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