public comment Articles

  • Bloomberg Environment Article “EPA Chemical ‘Rule’ Flouts Law, Ignores Risks, Critics Tell Court” Includes Comments By Lynn L. Bergeson

    On May 2, 2018, Bloomberg Environment quoted Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), regarding a brief filed by NRDC challenging the U.S. Environmental Protection Agency’s (EPA) New Chemicals Framework document. The NRDC’s brief did a good job buttressing its argument that the EPA’s framework warranted public notice and comment, Lynn L. ...


    By Bergeson & Campbell, P.C.

  • Suggested Method for Performing the Borehole Shear Test

    ASTM Committee D18.02 on Sampling and Related Field Testing for Soil Investigation (Mr. Ralph Brown, Chairman) suggested that this proposed suggested method be published herein to provide exposure and solicit comments for users. The purpose is to improve its clarity, accuracy, and acceptibility, so that in the future, Committee D18.02 may submit it for publication in the Annual Book of ASTM ...


    By ASTM International

  • EPA Issues Draft NMSP Concept Paper and TSCA Inventory Paper

    On July 12, 2007, the U.S. Environmental Protection Agency (EPA) published in the Federal Register three separate notices related to the long-awaited Nanoscale Materials Stewardship Program (NMSP) under the Toxic Substances Control Act (TSCA). See 72 Fed. Reg. 38,079-38,085 (July 12, 2007). . The first notice announces the availability of, and solicits public comment on, EPA’s proposed ...


    By Bergeson & Campbell, P.C.

  • U.S. EPA Proposes Overdue Refinery Air Rules

    U.S. EPA officially published revisions to the Maximum Achievable Control Technology (MACT) and New Source Performance Standards (NSPS) Refinery Air Rules (i.e., 40 CFR Part 60 Subparts J and Ja, and 40 CFR Part 63 Subparts CC and UUU, Refinery MACT 1 and Refinery MACT 2, respectively) today, ...


    By All4 Inc.

  • Proposed Revisions to the Guideline on Air Quality Models (Appendix W)

    On July 14, 2015, the U.S. Environmental Protection Agency’s (U.S. EPA’s) Office of Air Quality Planning and Standards’ (OAQPS) Air Quality Modeling Group provided a pre-Federal Register (FR) publication of the proposed revisions to the Guideline on Air Quality Models (Appendix W to 40 CFR Part 51) (Guideline) on the U.S. EPA’s Support Center for Regulatory ...


    By All4 Inc.

  • Bloomberg BNA Daily Environment Report Quotes Richard Engler In “No Insights in EPA Notices on 19 New Chemicals on Market”

    On April 25, 2017, Bloomberg BNA Daily Environment Report included comments by Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), commenting on the 19 new chemicals that have been given market approval by the U.S. Environmental Protection Agency (EPA) between December 1, 2016, and February 28, 2017. The EPA has notified the manufacturers that asked to make ...


    By Bergeson & Campbell, P.C.

  • EPA Issues Notice Of Proposed Settlement For Wyoming Refineries

    On September 14, 2015, the U.S. Environmental Protection Agency (EPA) published a Notice of Proposed Settlement Agreement; Request for Public Comment in the Federal Register. The notice is to settle lawsuits filed by Sinclair Wyoming Refining Company and Sinclair Casper Refining ...


    By Bergeson & Campbell, P.C.

  • Things not known

    Discovery and reporting are probably the two most important tasks facing responsible intellectuals. A serious problem appears, however, in regard to the linkage of the two efforts. Some authors provide conclusions without having undertaken the prior task of investigation. The problem appears in many works of popular writers, biographers, historians, social scientists, journalists, and free–lance ...


    By Inderscience Publishers

  • NOx and SOx Emissions Trading in Ontario

    Erik Haites outlines an unusual emissions trading programme due to begin next year. The government of Ontario recently announced its intention to establish an emissions trading programme for NOx and SOx emissions (oxides of nitrogen and sulphur) from all coal- or oil-fired electric generating plants in the province with a capacity greater than 25 MW beginning on 1 January 2001. This programme is ...

  • EPA Proposes Two Test Methods and Guidance for Evaluating Antimicrobial Pesticides

    The U.S. Environmental Protection Agency (EPA) has recently announced the availability of two proposed test methods and associated testing guidance for evaluating antimicrobial pesticides against two biofilm bacteria, Pseudomonas aeruginosa and Staphylococcus aureus, for comments.  EPA states that registrants of antimicrobial products with public health claims are “required to submit ...


    By Bergeson & Campbell, P.C.

  • Green 8 position paper on Proposal for a Directive of the European Parliament and of the COuncil on services in the internal market (The `Bolkestein Directive`)

    In this paper the eight undersigning environmental organisations limit their comments to the environmental dimension of the services Directive only, and do not focus on the wider issues that are under discussion at the moment. Birdlife International, Climate Action Network Europe, the European Environmental Bureau, the European Federation for Transport and Environment, the Environmental Network ...

  • Legal lookout: EPA updates IRIS process, again

    As EPA works to get its toxicological database back on track after lapsing for years, big questions arise as to the process' integrity. EPA announced in a May 21, 2009, memorandum that it has reformed the Integrated Risk Information System (IRIS), again. According to the agency, the revisions are intended to 'revitalize the program and ensure its scientific quality, integrity, transparency and ...


    By Bergeson & Campbell, P.C.

  • EAP seeks to lift stay

    Earlier this year, the U.S. Environmental Protection Agency (EPA) proposed lifting its 1994 administrative stay of Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 reporting requirements for hydrogen sulfide (H2S). Following is an explanation of why some are concerned, why EPA proposed lifting the stay, and why reporting may be unnecessary in the first place. How ...


    By Bergeson & Campbell, P.C.

  • A plea for patience and research on surface water connectivity in the U.S. Clean Water Act

    While winter has proven to be one of the coldest and snowiest seasons on record throughout much of the United States, the coming summer could be unseasonably warm in Washington, DC if the United States Environmental Protection Agency (USEPA) successfully implements its reinterpretation of one of the nation's proudest environmental regulatory accomplishments, the Clean Water Act (CWA). In 2013, ...


    By John Wiley & Sons, Ltd.

  • Legal Lookout: IRIS Redux

    EPA announced on May 21, 2009, that it has reformed the Integrated Risk Information System (IRIS). According to the agency, the revisions are intended to 'revitalize the program and ensure its scientific quality, integrity, transparency and timeliness.' The new administration In a May 21, 2009, memorandum, EPA Administrator Lisa P. Jackson stated that recent changes, including procedures ...


    By Bergeson & Campbell, P.C.

  • 55% of Award Projects Based on "Best Value"; SRS Crisafulli Responds

    SRS Crisafulli prides itself on the high quality, reliability and durability of its dredges, pumps and power units.  SRS Crisafulli asserts "Best Value" for its products.  But is "Best Value" always what our customers are looking for?  The July 2011 Public Works publication titled ' ...


    By SRS Crisafulli, Inc.

  • CPSC moves ahead on harmful products database

    Online resource will allow consumers to report issues and manufacturers to respond. The Consumer Product Safety Commission (CPSC) posted on its website on October 14, 2010, its draft final rule concerning the creation of a publicly available, searchable database on the safety of consumer products and other substances subject to CPSC regulation. The database is intended to provide a single point ...


    By Bergeson & Campbell, P.C.

  • Legal Lookout: EPA Staff Urges Changes in PM Standards

    Earlier this year, EPA staff scientists urged agency management to revise the current particulate matter (PM) standards for fine particles and the inhalable portion of coarse particles, based on evidence that suggests to EPA scientists that more protection is needed than is provided under current air standards. Background The Clean Air Act (CAA) requires that EPA periodically review its ...


    By Bergeson & Campbell, P.C.

  • EPA Releases Guidance Document: Antimicrobial Pesticide Use Site Index

    On July 24, 2015, the U.S. Environmental Protection Agency (EPA) issued a Federal Register notice extending the public comment period regarding its proposed Antimicrobial Pesticide Use Site Index (USI) from July 31, ...


    By Bergeson & Campbell, P.C.

  • NAS Releases Agenda for First Future Biotechnology Products and Regulatory System Committee Meeting

    On April 5, 2016, the National Academies of Science, Engineering, and Medicine (NAS) posted the Agenda for the ...


    By Bergeson & Campbell, P.C.

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