Dr. Richard E. Engler Makes Presentation Regarding TSCA Reform to the Chemical Society of Washington
On April 27, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), presented “Toxic Substances Control Act (TSCA) and TSCA Reform” at the Chemical Society of Washington’s monthly dinner meeting. Dr. Engler discussed TSCA before and after reform by The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) and challenges that the U.S. Environmental Protection Agency (EPA) and industry face in implementing and complying with the new law. In this extensive presentation, Dr. Engler discussed the centralizing concept of unreasonable risk in new TSCA, the evaluation of which:
- Does not include consideration of cost/benefit factors;
- Focuses on conditions of use as determined by EPA; and
- Includes consideration of potentially exposed or susceptible subpopulations identified as relevant by EPA.
Dr. Engler also covered key definitions within Lautenberg before diving into specific section-by-section changes to TSCA.